I am not a tax expert by any means but this seems very bad for Americans with golden visas. If I understand our double tax exclusion correctly, it seems that this 7500 minimum tax will not be deductible or creditable because it is not proportional to the taxable amount. Just as they give options to legacy NHR Scandinavians to avoid punitive taxation by opting in to the 10% tax, perhaps they could offer an alternative taxation rate to Americans that would essentially cancel out the tax rate that would otherwise be paid in the USA.