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.)
Presenter: Phil Hodgen