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1 kwi 2020 · 962 - 1, issued in March 2019, allows individuals to make a Sec. 962 election with respect to a GILTI inclusion. Taxpayers who make a Sec. 962 election for corporate rates may also deduct 50% of the amount of the GILTI inclusion under Sec. 250.
- Tax reform: Individual taxpayers and the Sec. 962 election
Sec. 962 allows an individual U.S. shareholder (including a...
- Tax reform: Individual taxpayers and the Sec. 962 election
1 paź 2018 · Sec. 962 allows an individual U.S. shareholder (including a trust or estate) to elect to be taxed at corporate income tax rates on certain Subpart F income under Sec. 951 (a).
All domestic corporations (and U.S. individual shareholders of controlled foreign corporations (CFCs) making a section 962 election (962 electing individual)) must use Form 8993 to determine the allowable deduction under section 250.
30 maj 2024 · A Section 962 election allows U.S. individuals to elect to be taxed on their GILTI and Subpart F income at corporate tax rates. When an individual makes this election, they are effectively treated as if they own their CFC through a hypothetical domestic corporation.
(b) Election An election to have the provisions of this section apply for any taxable year shall be made by a United States shareholder at such time and in such manner as the Secretary shall prescribe by regulations.
Use Form 8993 to figure the amount of the eligible deduction for FDII and GILTI under section 250. Who Must File All domestic corporations (and U.S. individual shareholders of controlled foreign corporations (CFCs) making a section 962 election (962 electing individual)) must use Form 8993 to determine the allowable deduction under section 250.
10 cze 2022 · When a U.S. individual makes a Section 962 election, the taxpayer is treated as owning the CFC through a fictitious domestic corporation. This enables the taxpayer to benefit from the 21-percent corporate tax rate as well as the Section 250 deduction (for GILTI purposes only).
