US shareholder of CFC elects corporate rates + FTC on GILTI, cutting rate from 37% to ~21%.
US citizens who own foreign corporations (CFCs) get hit with GILTI at ordinary rates (up to 37%) with no FTC as individuals. Making a §962 election allows the individual to be taxed as a C-corp on that income — 21% rate + 80% FTC on foreign taxes paid — often reducing effective US tax to 0% for high-tax-country CFCs. Downside: subsequent distributions taxed again as dividends.
Click Generate advisory deep dive for mechanics, IRC citations, a step-by-step execution plan, a worked numeric example on your profile, costs, risks, and this-week actions.
Exclude ~$130K/yr of foreign-earned income + housing exclusion — bona fide resident or 330-day test.
Dollar-for-dollar credit for foreign income taxes paid — no cap, no phase-out.
Establish residency in a 0-tax or territorial-tax country to escape US state tax + optimize CFC.
HSBC Expat, America Mortgages, Waltz, MBanc — 30-yr fixed US real estate loans for non-residents.
Non-US jurisdictions with no recognition of foreign judgments — bulletproof asset protection.
Claim treaty position to be taxed as resident of only ONE country, halving your compliance.
Non-resident aliens can own a US LLC, do US business, and pay $0 US tax if properly structured.
Second passport / residency via investment (Portugal, Malta, Greece, Caribbean, UAE, Panama).