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September 2020 International Tax Lunch: Section 962 – Should I be Taxed as Corporation?

Section 962 – Should I be Taxed as 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.)

Presenter: Phil Hodgen

Materials: Dropbox