“The Tax Cuts And Job Act brought in a whole new level. Small locally owned businesses we caught up in an effort to repatriate money from the likes of Google and Amazon. These small business owners were forced to recalculate their earnings dating back to 1986 (just like a large multinational corporation). The tax preparation for this alone could easily be in the tens of thousands of dollars. The retroactive back taxes will likely bankrupt thousands of businesses.”
The Section 965 “Transition Tax” saga continues. Americans abroad may have political differences. They may have philosophical differences. They may live in different countries with different tax treaties. But, opposition to the Section 965 Transition Tax and GILTI appear to have unified all Americans abroad.