Under the TCJA, with the corporate income tax rate of 21%, the 100% dividends received deduction (participation exemption), the 50% deduction for GILTI plus the limited deemed paid foreign tax credit associated with any such GILTI inclusion, and the 37.5% Foreign Derived Intangible Income (FDII) deduction, individual U.S. shareholders of FCs should consider whether or not a Code Section 962 election to be taxed as a domestic corporation should be made.

True

False