The Section 962 election allows individual U.S. shareholders of CFCs to elect to be taxed at corporate tax rates on their Subpart F income or GILTI inclusions. This election can provide a potential tax benefit by allowing the individual to claim a foreign tax credit for taxes paid by the CFC.
While the 962 election and the high tax exception are distinct provisions, they can interact. For instance, if an individual makes a 962 election, they might also benefit from the GILTI High Tax Exception, reducing the amount of GILTI inclusion subject to U.S. tax.