Page 196 - International Taxation IRS Training Guides

Deduction for
FDII and GILTI (Cont'd)

available to domestic corporation
 Deductions

• US individuals
can elect under IRC 962 to be subject to tax at
corporate rates and may
claim GILTI deduction (US individuals still
to shareholder-level tax on distribution)
subject

corporations or RICs or REITs
• Deduction not available for S

 If,
for any taxable year, the sum of a domestic
corporation’s FDII
and GILTI deductions exceed its

taxable income, the excess
is allocated pro rata to

reduce the corporation’s
FDII and GILTI solely for
purposes of
computing deduction

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