Page 605 - Large Business IRS Training Guides
P. 605
GILTI and Domestic
Partnerships 3
Aggregate treatment
USP
FP
To determine:
• The persons
that own stock of
> 50% < 50% the foreign corporation within
§958(a), i.e.,
the meaning of
who has
a GILTI inclusion.
treatment
Entity
US To determine whether:
PS • Any
US person is a US
shareholder,
US shareholder is a
• Any
controlling domestic
and
CFC1 CFC2 CFC3
shareholder;
• Any
foreign corporation is a
CFC
21
