Page 606 - Large Business IRS Training Guides

GILTI and Domestic
Partnerships 4

PS (direct owner of FC) and US Corp
• US
of 95% of FC under
(constructive owner

are US shareholders of FC.
§958(b)) US
Individual i s
not a US shareholder of FC.

a CFC because US shareholders
• FC i s
own more than 50%.

purposes of GILTI, only §958(a)
• For
owners
have to do a computation, and
for
this purpose, US PS is treated as
foreign,
resulting in US Corp owning 95%

of US Corp will
FC under §958(a)(2).
compute its
GILTI, and US PS and US
do not compute a GILTI
Individual
amount.

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