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Domestic partnerships are no longer required to complete Form 8992 or Schedule A (Form 8992). Instead, domestic partnerships must complete Schedule K-2 (Form 1065), Part VI, and Schedule K-3 (Form 1065), Part VI. Form 8993 deduction.
GILTI is calculated as the total active income earned by a US firms foreign affiliates that exceeds 10 percent of the firms depreciable tangible property.
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.
Foreign tax credits are allowed for foreign income taxes paid on GILTI included in the gross income of a domestic corporation.
What is GILTI? GILTI, or global intangible low-taxed income, is a deemed amount of income derived from CFCs in which a U.S. person is a 10% direct or indirect shareholder. It is computed, roughly, by determining the taxable income (or loss) of a CFC as if the CFC were a U.S. person.
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Controlled foreign corporations, or CFCs, are entities that are directly or indirectly more than 50% controlled by a U.S. parent but organized under foreign law. For U.S. income tax purposes, they are treated as corporations.
Who Is Subject to GILTI? A U.S. shareholder who directly or indirectly owns 10% or more of the vote or value of the stock of a CFC.
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.
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.
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.

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