§ 962 “Election by Individuals to be subject to Tax at Corporate Rates” of the Internal Revenue Code (“IRC” or “Code”) of the United States (“U.S.”) was treated as an “‘obscure little backwater’ area of the law” until the enactment of the Tax Cuts and Jobs Act of 2017 (“TCJA”) reduced the corporate tax rate to 21 percent. As the Global Intangible Low-Taxed Income (“GILTI”) affects the individual U.S. taxpayers who are shareholders in foreign corporations do not get the participation exemption, this § 962 has become very important. From the basic idea of humans being taxed as if they were corporations for some specific purposes, the § 962 election toggles a different tax result under four different IRC sections; it creates less inclusion in gross income, namely § 250 Foreign-Derived Intangible Income (“FDII”) and GILTI, which creates a lower tax rate by invoking the corporate income tax rate under § 11 “Tax Imposed” rather than the human tax rate under § 1 “Tax Imposed”. It also allows human beings to take the indirect foreign tax credit permitted by § 960 “Deemed-Paid Credit for Subpart F Inclusions”. Finally, § 962 obliterates the entirely fabulous § 959 “Exclusion from Gross Income of Previously Taxed Earnings and Profits” in which all dividends from controlled foreign corporations (“CFCs”) are tax-free, and instead substitutes a new rule stipulating that some of the dividends are going to be taxable indeed. From this perspective, an individual U.S. shareholder of a Korean corporate entity can take advantage of § 962 election as her tax can be calculated using the corporate tax rate of 21 percent and applicable deemed-paid foreign tax credits but always with the caveat of additional tax payable in future when actual dividends are paid. This adds complexity but can be a significant timing benefit in the right circumstances since there is a cash-flow advantage from delaying an actual tax payment to an indefinite future year. This article covers what problems the election solves and how it solves them and provides a specific overview of § 962 from the perspective of U.S. shareholders in Korean corporations.