Page 662 - Large Business IRS Training Guides

GILTI and Subpart
F

• A GILTI inclusion is similar, but not identical, to a subpart F
inclusion.
computed at the US shareholder level; subpart F
• GILTI is
income items (e.g.
FBCI) are determined at the CFC level.

• GILTI generally
allows a loss from one CFC to offset

income from
another CFC (i.e., net CFC tested income);
subpart
F income from one CFC generally may not be offset

subpart F loss of another CFC.
by

• GILTI i
s a taxable income concept (not limited to E&P);
F income is based on, and limited to, current E&P
subpart

(§952(c)(1))
increased by tested loss.

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