In case you missed it's release right before the President's Day holiday weekend, our International Tax Group addressed an election under Section 962 available to individual U.S. shareholders of certain foreign corporations to be taxed as a C corporation, which before tax reform was a rarely utilized and often forgotten tool that has recently been thrust into the spotlight due to its potential benefits.
The rise in popularity of the Section 962 election
Smith v. Commissioner, an unfavorable ruling for U.S. shareholders receiving distributions of foreign earnings subject to a Section 962 [...]Read more
Our International Tax Group takes stock of new proposed regulations that try to keep Section 956 relevant despite the Tax Cuts and Jobs Act.
Many were left scratching their heads
“A result directly at odds with the manifest purpose of Section 956”
Impact of the proposed regulations
Read the full advisory here. [...]Read more