• Monte Silver, Tax lawyer

Final GILTI-related regulations deliver HUGE win for our advocacy!

Updated: Jul 22




Today Treasury issued final regs related to GILTI. These regs relate directly to American expats and US based Americans that operate businesses overseas via a non-US corporation.


The regs provide us small business owners with three meaningul, permanent forms of relief. These forms of relief are 100% the result of our advocacy!


  1. The IRC 250 deduction is available to a taxpayer doing a 962 election.

  2. The 962 election is retro to Jan 2018, thus making the availablility of the IRC 250 deduction available from the beginning of GILTI

  3. A company can do a 962 election in an amended return

I am aware of no other expat advocacy EVER ever that achieved a final permanent fix!


To see the regs, https://drive.google.com/file/d/1u3d_aVLDV5J4ZeUwIqMfVt8RMPW52yMN/view?usp=sharing


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