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Trying to Reduce GILTI Tax Exposure? Why Streamlined Filing and Section 962 Planning Matter.
Section 962 is an election that lets individual U.S. shareholders of a Controlled Foreign Corporation (CFC) pay tax on GILTI and Subpart F inclusions at the 21% corporate rate instead of the 37% individual rate. The catch: when the CFC later distributes those earnings, you get taxed again as a qualified dividend. For prior unfiled