Page 604 - Large Business IRS Training Guides

GILTI and Domestic
Partnerships 2

of determining of GILTI:
• For purposes

• a domestic partnership is not treated as
owning the stock

of the foreign corporation within the meaning of
§958(a).

• a domestic partnership is treated as an aggregate of i t s

for purposes of determining who owns the stock
partners
of the foreign corporation within the meaning of
§958(a).

• This
matters because only persons who own stock of a

foreign corporation within the meaning of
§958(a) include

GILTI.

• It means that the partners of a domestic partnership, and not
partnership, would have to include any GILTI in
the domestic
their gross income.
See Treas. Reg. §1.951A-1(e).

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