Section 962 Election Articles

Making a Section 962 Election for Individual CFC Shareholders

A Section 962 election lets an individual U.S. shareholder calculate current-year CFC inclusion tax using corporate-style rules under Section 11, including corporate-style foreign tax credit mechanics under Sections 960(a) and 960(d), rather than staying fully on the ordinary individual path. The main tradeoff is timing. It may improve current-year cash retention, but later distributions can still trigger additional U.S. income to the extent earnings and profits exceed tax already paid under the election. Use it as a screening tool before you run a full model.