Form 8992 (Rev. December 2022). U.S. Shareholder Calculation of Global Intangible Low-Taxed Income (GILTI)-2025

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Form 8992 is required for U.S. shareholders of CFCs who own at least 10% of a foreign corporation, either directly or indirectly. U.S. citizens, green card holders, and resident aliens who own foreign corporations that meet the definition of a CFC must file this form if their foreign business generates net income.
(2) Tested income; tested loss For purposes of this section (A) Tested income The term tested income means, with respect to any controlled foreign corporation for any taxable year of such controlled foreign corporation, the excess (if any) of (i) the gross income of such corporation determined without regard to (I
Tax brackets 2024 (Taxes due in 2025) Tax RateSingle Filers/ Married Filing SeparateMarried Individuals Filing Jointly/ Qualifying Surviving Spouses 10% $0 $11,600 $0 $23,200 12% $11,600 $47,150 $23,200 $94,300 22% $47,150 $100,525 $94,300 $201,050 24% $100,525 $191,950 $201,050 $383,9004 more rows
This includes property used in a trade or business to produce DEI (tested income when calculating GILTI for a CFC). Common examples include machinery, buildings, and equipment. QBAI does not include land, intangible property, or assets that do not produce DEI.
Calculation: GILTI = Total Income - 10% of Tangible Assets.
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People also ask

As a result, the GILTI tax-rate spread is between 10.5% and 13.125%, ensuring at least a 10.5% minimum tax on foreign income and countering the tax advantage gained by strategically relocating IP assets in more tax-friendly locales.
GILTI is a tax applied to the revenue of non-U.S. companies that U.S. corporations and citizens control. These foreign companies, also known as controlled foreign corporations (CFCs), must be more than 50% owned by U.S. persons, and the U.S. shareholders must each own at least 10% of any stock in the CFC.
What is the TCJA tax on global intangible low-taxed income and how does it work? GILTI is the income earned by foreign affiliates of US companies from intangible assets such as patents, trademarks, and copyrights. The Tax Cuts and Jobs Act imposed a new minimum tax on GILTI.

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