Page 185 - International Taxation IRS Training Guides

GILTI Calculation

calculation applies a formulaic approach to
 GILTI

subject
income above a “normal return” to current
taxation

F, GILTI is determined at US
 Unlike subpart

shareholder level

 US shareholder
does not compute a separate GILTI
inclusion amount with respect
to each CFC but instead

inclusion amount by reference
computes a single GILTI
to all of its CFCs

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