The Phoenix Rises – Code Section 962 Election Is Back in Vogue

calendar iconJanuary 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.

This recent International Tax Journal article, authored by our own Michael Cornett, Director of International Tax Services, explores the Code Sec. 962 election, the mechanics of the Code Sec. 962 election and discuss some of the considerations that an individual U.S. Shareholder should contemplate when deciding to make the election.

For any questions about the Code Sec. 962, GILTI, Subpart F income or other international tax matters, contact your Cherry Bekaert professional.

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