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US International Tax Articles

Browse 3 Gruv blog articles tagged US International Tax. Coverage includes Tax Residency & Compliance. Practical guides, examples, and checklists for cross-border payments, tax, compliance, invoicing, and global operations.

Tax Optimization17 min read

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.

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Deep Dives17 min read

Subpart F Income for U.S. Shareholders of CFCs

If you are a U.S. shareholder of a foreign corporation that meets the CFC rules, **Subpart F is an anti-deferral rule that can pull income into your U.S. return before you receive cash**.

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Deep Dives16 min read

GILTI for U.S. Founders Abroad: A 3-Step Playbook

You need to make three decisions, in order. First, whether you are in scope. Second, which inputs create a current inclusion. Third, whether default treatment, a Section 962 election, or a structuring conversation is the right next move. If the global intangible low-taxed income, or GILTI, rules apply, your goal is a clear scope decision, a supportable exposure model, and a defined point where you escalate.

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