Section 962 Election Statement Template

Here are some considerations when making section 962 elections.

Section 962 election statement template. Tax return including amended returns but it will apply to all appropriate cfcs of the shareholder making the election for the year. But this election doesn t work as cleanly as one might hope or expect. An election made for any taxable year may not be revoked except with the consent of the secretary.

An election to have the provisions of this section apply for any taxable year shall be made by a united states shareholder at such time and in such manner as the secretary shall prescribe by regulations. Shareholder in a foreign business but careful consideration should be used before making the election. The election under section 962 may be made only by a united states.

There s a substantial compliance requirement involved in making the election including additional forms and statements that taxpayers must file. The section 962 election gilti gotcha. In this case does form 8992 not need to be used.

1 962 1 and 1 962 2 an individual u s. Proconnect has a field where you can enter the 962 tax and the election under other taxes schedule j. 962 election can be made on a year on year basis and is made on a timely filed u s.

Section 1 962 2 b lists the information that must be included on the irc section 962 election statement and i ve listed that regulation here for your easy reference to generate such statement. Depending on the specific circumstances using section 962 could result in an individual paying a greater effective rate of tax. Under section 962 of the code and treas.

The section 962 election may be a valuable tool in softening or deferring the double tax blow of being a u s. The section 962 election comes with a downside. In the final accounting therefore a section 962 election means some investor or entrepreneur might pay a very low tax rate on the imputed gilti income.