Considering the Sec 962 election: "Reduction in U.S. Corporate Tax Rates Will Significantly Impact Outbound Tax Planning by U.S. Individuals" taxeswithoutbordersblog.com/2018/01/reduct…

Sec. 962 to the Rescue thetaxadviser.com/issues/2015/au…

How Will TCJA Affect Individuals Electing Corporate Taxation? taxeswithoutbordersblog.com/2018/04/how-wi…

Section 962 Elections, GILTI, and "As If" in the Internal Revenue Code hodgen.com/section-962-el…

"America's bizarre relationship with citizenship" - @GusSwnsn medium.com/@greg_99089/am…

Correct: Those who are not in the system are not likely to enter the system. Those who are in the system are now in a position where compliance is almost impossible. This is what it means to be an U.S. citizen living outside America in he 21st century.

The new GILTI and repatriation taxes: Issues for flowthroughs thetaxadviser.com/issues/2018/ju…

Global Intangible Low Tax Income (GILTI) and Foreign-Derived Tangible Income Taxes (FDII) blog.freedmaxick.com/summing-it-up/…

Tax Reform and Global Intangible Low-Taxed Income | BDO bdo.com/insights/tax/i…

The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc. - tinyurl.com/yaz4cp86 via MNE Tax

Cushioning the double-tax blow: the section 962 election (applied to both #GILTI and the U.S. Transition Tax - Subpart F and #GILTI rsmus.com/what-we-do/ser…

Section 962 Election: An Answer to GILTI? evergreensmallbusiness.com/962-election-a…

Interesting discussion of a possible election to change entity classifications on a going forward basis: "Will Your Small Business Owe #GILTI Tax?" evergreensmallbusiness.com/will-your-smal…

Why the Moore MRT AKA U.S. Transition Tax - Subpart F and #GILTI appeal is the most important case the the US Supreme Court has ever heard. The Court stands between the possibility of freedom and a society ruled completely but the IRC. youtube.com/live/a3iqDqIBr…

The Moore case, which is based on the injustice and unconstitutionality of the U.S. Transition Tax - Subpart F and #GILTI will be heard by the US Supreme Court. Follow the progress (and briefs including the brief from AARO and SEATNow.org - Stop Extraterritorial American Tax) here: supremecourt.gov/search.aspx?fi…

.SEATNow.org - Stop Extraterritorial American Tax and AARO Join to File Amicus Brief in Moore seatnow.org/2023/09/05/sea… via SEATNow.org - Stop Extraterritorial American Tax