AARO member Monte Silver announced in an email earlier this week that after the hard work of many organizations and individuals, the US Treasury Department and IRS have granted some relief to Americans professionals and business owners abroad who are subject to the Repatriation taxes. (See this AARO report for more information.)
Relief is not repeal, but Silver says that it is, nonetheless, "meaningful relief." He writes:
A US living abroad who is an individual US shareholder of a controlled foreign corporation shall incur no acceleration of the 8 year payment plan, or other penalties, for failing to make the June 15, 2018 payment, if the total tax due from the expat under the Repatriation tax (i.e. in all the eight years) is less than $1,000,000.
In other words, business owners and professionals subject to these taxes must still file and make the 965(h) election by June 15, 2018 (or October 15, 2018 if a valid extension has been filed), but are not required to make a payment on that date if the total amount of tax due is under 1,000,000 USD.
Links to other articles on-line:
The Financial Times article Expat Americans given on-year reprieve on US repatriation tax
American Citizen's Abroad (ACA) press release The Internal Revenue Service Has Offered Penalty, Filing Relief to Many Who Are Subject to the New Transition Tax on Foreign Earnings