IRS Form: Reporting GILTI Income (IRC §951A)

Form 8992, U.S. Shareholder Calculation of Global Intangible Low-Taxed Income (GILTI), released January 8. 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 any controlled foreign corporation for any taxable year of such U.S. shareholder must include in gross income such ...