From Obscurity to Spotlight: The Section 962 Election

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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 election
  • When to contemplate a Section 962 election

Ready the full advisory here.