9/2018 Publications

Cushioning the Double-Tax Blow: The Section 962 Election

The passage of the 2017 Tax Cuts and Jobs Act (TCJA) was heralded as the beginning of a new age in international taxation. Finally, the injustice of the double tax on dividends received by United States shareholders from foreign corporations was put to rest for good … at least for those United States shareholders who were also already using a corporate tax structure. For those who were not, some temporary relief may be available in the form of a section 962 election. RSM US LLP. September 21, 2018 (Republished March 8, 2019).

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