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.

Registration for this course has passed.

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

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This course does not qualify for CPE Choice.

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