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An S corporation that elects to be treated as an entity under Notice 2020-69 must complete Form 8992 and Schedule A (Form 8992) and attach them to its Form 1120-S by the due date (including extensions) for that return. For additional information, see the Instructions for Form 1120-S.
Form 8992 Schedule A for GILTI It is important to note that not all US shareholders with foreign corporations will have to calculate GILTI as part of their U.S. tax return. Rather, it is limited to shareholders who own Controlled Foreign Corporations or CFC and meet other requirements as well.
The GILTI rules (contained in the new section 951A) require a 10 percent U.S. shareholder of a controlled foreign corporation (CFC) to include in current income the shareholders pro rata share of the GILTI income of the CFC. The GILTI rules apply to C corporations, S corporations, partnerships and individuals.
An S corporation that elects to be treated as an entity under Notice 2020-69 must complete Form 8992 and Schedule A (Form 8992) and attach them to its Form 1120-S by the due date (including extensions) for that return.
Who Needs To File Form 8992. Any U.S. shareholder of one or more CFCs that must take into account its pro rata share of the tested income or tested loss of the CFC(s) in determining the U.S. shareholders GILTI inclusion, if any, under section 951A must file the Form 8992.
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GILTI is income earned abroad by controlled CFCsi.e., controlled subsidiaries of U.S. corporationsfrom easily movable intangible assets, such as IP rights. The tax on GILTI is intended to discourage moving intangible assets and related profits to countries with tax rates below the 21% U.S. corporate rate.
Specified interest expense includes the interest expense of all CFCs, including those with a tested loss. A U.S. shareholder of a CFC that owns stock of the CFC within the meaning of IRC 958(a) must include in gross income its GILTI for the taxable year.
Form 1118 lets foreign corporations report the income they already owe taxes on to a foreign government so that it can be exempted from US taxation. This credit only applies to income taxes, not value-added taxes or sales taxeseven in countries where a value-added tax is used as a substitute for income taxes.
U.S. shareholders must file Schedule I-1 (Form 5471), Information for Global Intangible Low-Taxed Income and Form 8992, U.S Shareholder Calculation of Global Intangible Low-Taxed Income (GILTI) , to provide the information needed to determine the U.S. shareholders GILTI inclusion amount for a tax year.
Who Needs To File Form 8992. Any U.S. shareholder of one or more CFCs that must take into account its pro rata share of the tested income or tested loss of the CFC(s) in determining the U.S. shareholders GILTI inclusion, if any, under section 951A must file the Form 8992.

8992 schedule a