The IRS issues proposed regulations on Sec. 250, providing favorable treatment for individual taxpayers with a GILTI inclusion who make an election under Sec. 962. Ordinarily, this was only available to C corporations.
In our alert, we discuss:
- What is GILTI.
- GILTI for individual taxpayers.
- Sec. 962 elections.
- When an individual should elect Sec. 962 on GILTI.