Shareholder Election to be taxed as a U.S Corporation

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In a controlled foreign corp subpart f income is distributed to the U.S individual shareholder with no foreign tax credit available. However this election is apparently available as follows. HAS ANYBODY HAD EXPERIENCE WITH THIS ? IS THERE A DOWNSIDE ?

From "Controlled Foreign Corporation Tax Guide"

IRC Section 962 permits an individual shareholder of a CFC to be taxed (on the shareholder's proportionate share of the subpart F income of the CFC) as if the shareholder were a domestic corporation.

The primary benefit of this provision is that an individual shareholder will be
permitted to claim a foreign tax credit for foreign taxes paid by the foreign
corporations in which the taxpayer is a shareholder. Domestic corporations are permitted to claim a foreign tax credit for foreign taxes imposed on the subpart F income of CFCs in which the domestic corporation is a "U.S. shareholder.â€￾

Individuals who are "U.S. shareholders" of a CFC are not entitled to claim a
foreign tax credit for taxes paid by the foreign corporation unless they make this election under IRC Section 962.

Where an individual owns a 10% or greater interest in more than one CFC, the election applies to all of the CFCs in which the individual is a "U.S. shareholder" of a CFC.43

The election may only be made by an individual, an estate or a trust.

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Here is the downside:


"Individual U.S. shareholders are not entitled to use this foreign tax credit
mechanism unless they elect, in essence, to be taxed on subpart F inclusions at the combined U.S. corporate and individual effective tax rate of over 54%. "