IRS Form: Draft Instructions for Form Used to Calculate GILTI (IRC §951A)

Draft Instructions for Form 8992, U.S. Shareholder Calculation of Global Intangible Low-Taxed Income (GILTI), released December 18 to reflect final regulations (T.D. 9866), regarding the determination of the amount of gross income of U.S. shareholders of foreign corporations, including those that are members of a consolidated group. Changes to Form 8992 include revising Part II to reflect the U.S. shareholder’s calculation of specified interest expense using the netting approach, and a new column in Schedule A to report a CFC’s pro rata share of tested loss qualified business asset investment amount. [Draft Instructions for IRS Form 8992 ...