Complimentary for Members

October 27, 2026

Live Webcast

NYSED 1
•
NASBA 1

Maximizing the High-Tax Exclusion vs. the Sec. 962 Election for Individual CFC Shareholders

October 27, 2026
Live Webcast
NYSED 1
•
NASBA 1

Maximizing the High-Tax Exclusion vs. the Sec. 962 Election for Individual CFC Shareholders

  • View Bio

    Instructor

    Natallia
    Shapel

    View Bio

    Ms. Natallia Shapel, CPA

    Bio
    Natallia has over 18 years of public accounting experience delivering tax consulting and compliance services to public and private companies. Natallia specializes on advising US and foreign multinationals on various aspects of international tax laws, including tax planning and structuring of U.S. in- and outbound investments, supply chain planning, cross-border reorganizations, tax treaties, due diligence and U.S. tax compliance. In addition, Natallia has significant experience successfully representing taxpayers during international tax examinations.

This session explores the impact of the post-OBBBA framework on CFC taxation and individual U.S. shareholders. It compares the GILTI High-Tax Exclusion and Section 962 election, highlighting key international tax planning considerations.

Learning Objectives

  • Explain the impact of the post-OBBBA framework on individual CFC shareholders and tax deferral strategies.
  • Compare the GILTI High-Tax Exclusion and Section 962 election as tax planning alternatives for individual U.S. shareholders.
  • Analyze foreign tax credits, earnings repatriation, PTEP, and long-term exit considerations when selecting tax planning strategies.

Major Topics

  • Post-OBBBA CFC Taxation
  • GILTI and Section 962
  • International Tax Planning Considerations

CPE Credits Available

NYSED 1
NASBA 1
1
Taxation (NYSED) - NYSED
1
Taxes (NASBA) - NASBA

Things to Know About This Course

Course Level

  • Intermediate

Professional Area of Focus

  • Taxation

Prerequisites

None.

Intended Audience

Tax Professionals with Individual and Businesses owning Controlled Foreign Corporations.

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