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Tax Notes International, August 10, 2020, published by Tax Analysts

Expat Group Incensed Over GILTI Regs’ Small Business Brush-Off

"An advocacy group representing the interests of American expatriates is calling Treasury out on its global intangible low-taxed income high-tax exclusion rules for what it views as a dereliction of duty owed to small businesses.

In an August 6 release, American Citizens Abroad (ACA) attacked Treasury’s attempts to “tread carefully” around the Regulatory Flexibility Act (RFA) in its July 20 final regs (T.D. 9902) on the exclusion."