Page 660 - Large Business IRS Training Guides

GILTI
Inclusions for Individual US Shareholders

• Individual US
shareholders are generally not eligible for

the deduction under
§ 250 or FTCs with respect to GILTI.

individual US shareholders that elect under
• However,

§962 to be taxed at corporation rates may reduce their
the portion of the § 250 deduction that
taxable income by

would be allowed and claim
FTCs under § 960 with
Proposed §1.962-1(b)(1)(i)(B)(3).
respect to GILTI.

§ 962 does not put individual US shareholders on
• But
equal
footing with corporate US shareholders, because

individuals
with a § 962 election in place are taxed a
second time when the CFC
distributes its earnings.

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