Page 288 - International Taxation IRS Training Guides

Compare
BOY and EOY GTOC (Cont’d)

are identified,
 Once the entity structure changes

to the US tax attributes of the
analyze the changes
reporting entity

 Examples
of how the tax attributes may be affected:

• Non-taxable income inclusions

• Increase in FTC
taken

decrease in
• Increase in Foreign Sourced Income (FSI),
sourced income
US

• Increase in US
sourced expenses

• Income producing assets
moved onshore or offshore
• Character of
income as eligible for deferral vs. subpart F
or
GILTI

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