Page 186 - International Taxation IRS Training Guides

GILTI Calculation (Cont’d)

inclusion amount begins with the calculation of
 GILTI
each CFC
certain items of

tested loss determined at each CFC, and pro rata
• Tested income or
tested income or tested loss flows up to each US
share of
and netted at US shareholder level to determine US
shareholder
shareholder’s
net CFC tested income

• Qualified business asset
investment (QBAI) and interest expense
each CFC, and pro rata share of QBAI from tested
determined at
up to each US shareholder
income CFCs and interest expense flows
to determine US shareholder’s
QBAI and interest expense

income return (net DTIR) is 10% of QBAI
– Net deemed tangible
less certain interest expense

• Net CFC tested income less net DTIR
equals GILTI

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