Prologue https://t.co/NsiE50Ojve pic.twitter.com/kwNOMXUsGw β John Richardson β lawyer for "U.S. persons" abroad (@ExpatriationLaw) March 15, 2020 Americans abroad who are individual shareholders of small business corporations in their country of residence have been very negatively impacted by the Section 951A GILTI and Section 965 TCJA amendments. In June of 2019, by regulation, Treasury interpreted the β¦













