International Tax Blog

GILTI Deduction Allowed With 962 Election (Proposed Regulations)

The IRS has issued proposed regulations on the GILTI deduction under Code §250. The proposed regulations indicate that a GILTI deduction will be available for an individual who makes a Code §962 election to be taxed at corporate rates. The preamble to the proposed regulations provides in part: Congress enacted section 962 to ensure that individuals’ tax burdens with respect to undistributed foreign earnings of their CFCs “will be no heavier than they would have... Read more →

Famous Tax Quotes - That’s How The Cookie Crumbles

Continuing our series on Famous Tax Quotes (quotes from court opinions and rulings with language that is colorful or that concisely states an important tax principle) today's tax quote is: When filing their amended returns for 2004 and 2005, petitioners made voluntary, irrevocable elections under section 962. * * * By making these elections petitioners got what they bargained for * * * [T]hese elections may ultimately cause them to include more gross income than... Read more →