IRS Form: Attaching Form 8992 to Partnerships Form 1065 (IRC §958)

A domestic partnership is not required to attach to its Form 1065 a Form 8992, U.S. Shareholder Calculation of Global Intangible Low-Taxed Income (GILTI), with the domestic partnership’s identifying information and a completed Schedule A, for a CFC if the partnership is a U.S. shareholder within the meaning of tax code Section 951(b) solely by reason of applying Section 318(a)(3) (providing for downward attribution) as provided in Section 958(b), the IRS provided in clarifying the instructions. However, a domestic partnership that is a U.S. shareholder in a CFC and owns any of the CFC stock ...