Page 609 - Large Business IRS Training Guides

GILTI Formula 2

Net
CFC
GILTI
=
-
Net DTIR

Tested Income

10% of
Pro rata share
Pro rata share
aggregate Specified

of aggregate
less
of aggregate
pro rata less interest
tested income
tested loss
share of expense
QBAI

Aggregate pro Aggregate pro
rata share of rata share of
tested interest less tested interest
expense income

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