Introduction: As Goes Tax Reform For US Multinationals, So Escalates The Harm To Individual Americans Abroad
— John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) April 14, 2021
The Problem: The proposed changes in International Tax (mostly in relation to corporations) will affect numerically more individuals than corporations. The effects on Americans abroad, who run small businesses outside the United States, will be absolutely devastating.
Two Solutions: Suggestions for how to protect individuals (including Americans abroad) would be to make changes to the Subpart F regime – GILTI, etc. There are at least two ways this change can be achieved: