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Kellie Becker Ben Cote Arthur Ruple
March 15, 2019 Article 5 min read
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.

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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.