It is perhaps that they want to increase the US tax revenue without effecting the general public but they may suppose that those living abroad may not be so loud in protesting the increases that might occur to Expats. Otherwise who know the intent of some of their hearts in what they try to do.

Americans abroad who are individual shareholders of small business corporations in their country of residence have been very negatively impacted by the Section 951A GILTI and Section 965 TCJA amendments. In June of 2019, by regulation, Treasury interpreted the 951A GILTI rules to NOT apply to active business income when the effective foreign corporate tax rate was at a rate of 18.9% or higher. Treasury’s interpretation was reasonable, consistent with the history of Subpart F and consistent with the purpose of the GILTI rules. Now, Senators Wyden and Brown are attempting to reverse Treasury’s regulation through legislation. This is a direct attack on Americans abroad. Read this article: www.taxconnections.com/taxblog/seriously-now-whos-gilti-senators-wyden-and-brown-attempt-to-reinforce-the-punishment-of-gilti-americans-abroad/

Americans abroad who are individual shareholders of small business corporations in their country of residence have been very negatively impacted by the Section 951A GILTI and Section 965 TCJA amendments. In June of 2019, by regulation, Treasury interpreted the 951A GILTI rules to NOT apply to active business income when the effective foreign corporate tax rate was at a rate of 18.9% or higher. Treasury’s interpretation was reasonable, consistent with the history of Subpart F and consistent with the purpose of the GILTI rules. Now, Senators Wyden and Brown are attempting to reverse Treasury’s regulation through legislation. This is a direct attack on Americans abroad. Read this article: www.taxconnections.com/taxblog/seriously-now-whos-gilti-senators-wyden-and-brown-attempt-to-reinforce-the-punishment-of-gilti-americans-abroad/