What is the Section 962 election and why would an individual CFC shareholder make it?
I'm a U.S. citizen who owns a CFC through a personal holding structure (not through a U.S. corporation). My CPA says I should consider a 'Section 962 election' to reduce my tax on GILTI and Subpart F income. She says it lets me get taxed at corporate rates instead of my individual rate. How does this work? What are the benefits and downsides? And what happens when the CFC eventually distributes the income as a dividend?
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