New Regulations Clarify Expatriates' Corporate Conversion - McDermott Will & Emery

New Regulations Clarify Expatriates’ Corporate Conversion

Overview


Steven Hadjilogiou commented on the IRS and Treasury Department’s proposed new rules on taxing international income that would allow individual expatriate owners to reclassify themselves as corporations and still qualify for the GILTI deduction. “They’ve made it explicitly clear that you do get the deduction if you make this election,” said Hadjilogiou.