Page 670 - Large Business IRS Training Guides

Taxpayer Planning

Taxpayers
may try to reduce GILTI and the resulting tax by…

for an individual to be taxed at
• Making a 962 election
corporate
rates.

• Checking
the box to treat CFCs as DEs of a Super Holdco

CFC

expenses to non-GILTI FTC baskets and/or
• Allocating
construing taxes attributable to GILTI
broadly

• Selling specified
tangible property to related CFC to increase
tax basis

• Planning
into subpart F income

• Adjusting
transfer pricing to avoid tested loss CFC

• Other

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