Individual owners of foreign corps elect corporate treatment to access 50% GILTI deduction + FTC.
US individuals owning CFCs (foreign corps) get slammed with GILTI at ordinary rates with NO foreign tax credit. A §962 election lets them be taxed AS IF they were a C-corp — accessing the 50% §250 GILTI deduction and foreign tax credits. Drops effective GILTI rate from 37% to ~10.5% or lower. Essential for US owners of foreign operating companies.
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Multiply the $10M §1202 exclusion across multiple trusts.
4% corporate tax + 0% capital gains for bona fide residents.
Stack the $500K primary-home exclusion on top of a 1031 deferral.
Convert Traditional to Roth during sabbaticals or business-loss years.
Capitalize property taxes and interest on undeveloped land.
Deduct now, control forever, employ heirs.
Ordinary loss (not capital loss) on failed small biz — up to $100K.
Buy leveraged real estate inside your IRA — tax-deferred or tax-free.