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In proposed GILTI regs, Treasury grants businesses with relief. This is a direct result of our advocacy!!!
Under the proposed regs, a small business owner will avoid GILTI tax liability so long as the business is located in countries where the corporate tax rate is greater than 13%
See https://drive.google.com/file/d/1fJ-dvZXmZ8zILXauWq7Uh0mPTo5Xwmij/view?usp=sharing