The Phoenix Rises – Code Section 962 Election Is Back in Vogue
January 12, 2022
In 2017, the Tax Cuts and Jobs Act (“TCJA”) expanded the Code Sec. 962 regime to include global intangible low-taxed income (“GILTI”). Under that regime, U.S. Shareholders of a Controlled Foreign Corporation (“CFC”) include in their taxable income their prorate share of certain items of income earned by the CFC (“Subpart F income”) on an annual basis.
For any questions about the Code Sec. 962, GILTI, Subpart F income or other international tax matters, contact your Cherry Bekaert professional or Mike Cornett.
This article is reprinted with the publisher’s permission from the International Tax Journal a bi-monthly journal published by WOLTERS KLUWER. Copying or distribution without the publisher’s permission is prohibited. To subscribe to the International Tax Journal or other WOLTERS KLUWER Journals please call 800-449-8114 or visit www.cchcpelink.com.