Page 643 - Large Business IRS Training Guides

GILTI Inclusion

• A US shareholder
of a CFC that owns stock of the CFC within the meaning of
must include in gross income its GILTI for the taxable year.
§958(a)
§951A(a).

• A US shareholder’s
GILTI inclusion under §951A is treated as an amount
included under
§951(a)(1)(A) for certain provisions of the Code, including:

and profits (PTEP) (sometimes called PTI)
• Previously-taxed earnings
(§959),

• Basis adjustments (§961),

• §962 elections,

& (d)(1), and
• §1248(b)(1)

• Six-year statute of limitations §6501(e)(1)(C).

to extend treatment to other Code sections by regulation
• There is authority
under
§951A(f)(1)(B).

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