Attorney Robert J. Misey, Jr. offers advice published in the December/January (2018) Journal of Tax Practice & Procedure, " How to Elect Code Sec. 962 Treatment New Uses for an Old Tool."
Since the 2017 Tax Reform Act passage, international tax professionals have advised U.S. individuals to consider making a Code Sec. 962 election. Now, international tax professionals are considering use of the Code Sec. 962 election to reduce the U.S. taxation of Global Intangible Low-Taxed Income.
Misey is a shareholder in Reinhart's Tax and Corporate Law Practices and chair of the firm's International Practice.
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