city skyscrapers
21 April 2026

Andersen Managing Directors Joe Calianno and Sean Dokko’s article The Section 962 Election: Benefits, Limitations, and the Interaction with the Net CFC Tested Income High Tax Exclusion is featured in Corporate Taxation (May/June), Journal of Taxation (May/June), and Practical Tax Strategies (July 2026). The article examines the mechanics of making the election, its benefits and limitations, and provides a framework to assist practitioners in determining whether the election is appropriate for their individual shareholder clients.