26 U.S.C. § 962 : US Code - Section 962: Election by individuals to be subject to tax at corporate rates

Search 26 U.S.C. § 962 : US Code - Section 962: Election by individuals to be subject to tax at corporate rates

(a) General rule
Under regulations prescribed by the Secretary, in the case of a
United States shareholder who is an individual and who elects to
have the provisions of this section apply for the taxable year -
(1) the tax imposed under this chapter on amounts which are
included in his gross income under section 951(a) shall (in lieu
of the tax determined under sections 1 and 55) be an amount equal
to the tax which would be imposed under sections 11 and 55 if
such amounts were received by a domestic corporation, and
(2) for purposes of applying the provisions of section 960
(relating to foreign tax credit) such amounts shall be treated as
if they were received by a domestic corporation.
(b) Election
An election to have the provisions of this section apply for any
taxable year shall be made by a United States shareholder at such
time and in such manner as the Secretary shall prescribe by
regulations. An election made for any taxable year may not be
revoked except with the consent of the Secretary.
(c) Pro ration of each section 11 bracket amount
For purposes of applying subsection (a)(1), the amount in each
taxable income bracket in the tax table in section 11(b) shall not
exceed an amount which bears the same ratio to such bracket amount
as the amount included in the gross income of the United States
shareholder under section 951(a) for the taxable year bears to such
shareholder's pro rata share of the earnings and profits for the
taxable year of all controlled foreign corporations with respect to
which such shareholder includes any amount in gross income under
section 951(a).
(d) Special rule for actual distributions
The earnings and profits of a foreign corporation attributable to
amounts which were included in the gross income of a United States
shareholder under section 951(a) and with respect to which an
election under this section applied shall, when such earnings and
profits are distributed, notwithstanding the provisions of section
959(a)(1), be included in gross income to the extent that such
earnings and profits so distributed exceed the amount of tax paid
under this chapter on the amounts to which such election applied.