The final regulations on the Internal Revenue Code1 Section 250 deduction for global intangible low-taxed income (GILTI) and foreign-derived intangible income (FDII) (TD 9901) (the Final Regulations) significantly affect individuals and certain trusts that hold direct and indirect interests in controlled foreign corporations (CFCs) and make elections under Section 962. Section 962 elections allow individuals and certain trusts that are US shareholders of CFCs to be taxed on GILTI and subpart F income as if they were a domestic corporation.This Tax Alert addresses how the Final Regulations affect Section 962 elections. This Alert also highlights certain reporting requirements relevant to partnerships with domestic corporate partners.For...