About Form 8992, U.S. Shareholder Calculation of ... - IRS-2025

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Form 8995 is the IRS tax form that owners of pass-through entitiessole proprietorships, partnerships, LLCs, or S corporationsuse to take the qualified business income (QBI) deduction, also known as the pass-through or Section 199A deduction.
Under section 951A, U.S. shareholders who own (within the meaning of section 958(a)) stock in a CFC are required to include GILTI in gross income. Form 8992 is used by a U.S. shareholder to calculate the amount of the GILTI inclusion and to report related information.
Like other information returns pertaining to foreign corporations, the penalty is $10,000 for failure to file this form, or provide all the required information. Failure to file after notification by the IRS incurs an additional penalty per month of up to $50,000. (Treasury Reg. Section 1.6038-5.)
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.
If the employer has contracts with more than one insurer or agent, the employer must file a separate Form 8922 for the wages and taxes related to each contract. supplying the name and EIN, and then file one Form 8922 for the wages and taxes related to the employers for which it isnt supplying the name and EIN. Box 1.

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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.
Calculation: GILTI = Total Income - 10% of Tangible Assets.

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