Page 663 - Large Business IRS Training Guides

Key
Differences

GILTI Subpart
F Income

level concept • CFC level concept
• US shareholder

• Inclusion is a formula-driven • Inclusion is based on

computation not dependent specifically defined types
of
on the type of income income

• Losses from • Subpart F income of one
one CFC may
is not offset by losses of
offset income from CFC
another
CFC another CFC

concept; limited to
• Taxable income concept; not • E&P

limited to E&P CFC’s current E&P
(increased by
tested loss)

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