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

Course Details


Friday, December 13, 2019

10:00am – 11:00am
(Registration: 9:30am)

Field of Study


Course Number


CPE Credit

1 hour CPE credit

Level of Knowledge



CalCPA Education Foundation




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.)


  • 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. 


  • 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?

Designed For

Lawyers and CPAs.

Course Pricing

Member Fee

Applicable if you are a HSCPA member in good standing.

Non-Member Fee

Applicable if you are not a HSCPA member.

Your Price $50.00

CPE Choice

Learn more about CPE Choice.
This course does not qualify for CPE Choice.

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