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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.
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.
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.
Each U.S. shareholder (10% or more owner) of a CFC will pick up its pro rata share of the GILTI inclusion items (tested income, etc.)
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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.
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.
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.
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.
More In Forms and Instructions U.S. shareholders of controlled foreign corporations use Form 8992 and Schedule A to figure their global intangible low-taxed income inclusions under section 951A and its related regulations.

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