International Tax Lunch: Section 962ƒ?"Should I Be Taxed As A Corporation?

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1.0 Credits

The new international tax rules now make most foreign corporation income immediately taxable to U.S. shareholders (via the Subpart F and GILTI rules). Section 962 gives individual taxpayers an election to be taxed on Subpart F income and GILTI at corporate tax rates (21%) rather than individual tax rates (as high as 37%).

Should individual shareholders make this election? (Hint: the election's consequences are not all rainbows and unicorns.)


  • How does the Section 962 election work?
  • The three changes that the election makes to an individual shareholder's calculation of tax liability.
  • How does a Section 962 election compare to other tax strategies for individual shareholders of foreign corporations?

Major Topics

  • Subpart F income
  • GILTI.
  • Taxation of individual shareholders of controlled foreign corporations.
  • Direct and indirect foreign tax credit.
  • The IRC §962 election.
  • Holding structure choices for American shareholders in foreign corporations. 

Designed For

Lawyers and CPAs.



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