International Tax Lunch: Section 962?"Should I Be Taxed As A Corporation?
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
- 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?
Lawyers and CPAs.
Applicable if you are a HSCPA member in good standing.
Applicable if you are not a HSCPA member.