Page 644 - Large Business IRS Training Guides

Allocation of
GILTI among CFCs

GILTI is allocated among CFCs with
• US shareholder’s
to which the shareholder is a US shareholder.
respect

§951A(f)(2)
and Treas. Reg. §1.951A-5(b)(2).

of GILTI allocated to a CFC is:
• Amount

• If CFC has no tested income, zero, and

• If CFC has tested income, proportionate amount based
on relative tested income of
each such CFC.
§951A(f)(2).

GILTI with regards to a particular CFC is
• Amount of

for example, in determining deemed paid taxes,
relevant,
PTEP,
and basis adjustments with respect to the CFC.

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