IRS Form: Draft Global Intangible Low-Taxed Income Forms (IRC §250)

Draft Form 8992, U.S. Shareholder Calculation of Global Intangible Low-Taxed Income (GILTI), and Form 8993, Section 250 Deduction for Foreign-Derived Intangible Income (FDII) and Global Intangible Low-Taxed Income, released August 22. The 2017 tax act (Pub. L. No. 115-97) added tax code Section 250 to impose a tax on “global intangible low-taxed income” (GILTI) of U.S. shareholders of CFCs, with a deduction of 37.5% for foreign-derived intangible income (FDII) plus 50% of the GILTI, and the amount treated as a dividend under Section 78. Under Section 951A, U.S. shareholders of ...