Introduction On April 14, 2021 Tax Notes published my post “To Punish 100 GILTI Corporations Is To Punish Millions More Individuals“. The purpose of that post was to describe the harm that President Biden’s proposed changes to GILTI would inflict on individual shareholders of CFCS generally and on expat entrepreneurs in particular. I proposed two possible solutions: 1. Exempting individuals from the Subpart F regime; or 2. Exempting individuals who would qualify for the 911 Foreign Earned Income Exclusion from the Subpart F regime. This post, written by Dr. Karen Alpert of SEAT, proposes a third way to both have reform to the GILTI rules and NOT inflict unnecessary harm on individuals. What follows is Dr. Alpert’s post as it appeared on the SEAT site. https://twitter.com/ExpatriationLaw/status/1384502158092128261
How To Fix The Proposed GILTI Changes – Dr. Karen Alpert
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