Section 962: Should I be Taxed as Corporation? Webcast | 4203817A
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.)
*Recognize effects of Section 962 election
*Determine whether Section 962 election is beneficial in a variety of structures
Applicable if you are a HSCPA member in good standing.
Applicable if you are not a HSCPA member.