My CPA says I might make a section 962 election because of GILTI. Is that an entity change or only a tax-election change for me personally?
I am a U.S. individual who owns a foreign corporation directly. My CPA said section 962 might help because of the GILTI inclusion, but I keep hearing people describe it almost like creating a temporary domestic corporate wrapper around the foreign company. That sounds confusing and maybe too simplified.
I want to know what actually changes when the election is made. If the foreign corporation stays the same and the election only changes my personal tax treatment, that is a very different planning conversation from the one I have been hearing in founder circles.
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