Page 657 - Large Business IRS Training Guides

Step 4

Allocate the US shareholder’s GILTI among CFCs
Step 4:

CFC’s Allocated GILTI = GILTI x (CFC’s Tested Income ÷ Aggregate CFC Tested Income)

CFC1 = 590 x 500x ÷ 900x = 328x

CFC2 = 590 x 100x ÷ 900x = 65x

CFC3 = 590 x 300x ÷ 900x = 197x

CFC4 = 590 x 0x ÷ 900x = 0

Question: Why do we allocate GILTI among the CFCs?

Answer:
PTEP, basis adjustments, FTCs, and future §986(c) FX gain/loss.

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