A Review of the 2021 Form 8992-U.S. Shareholder Calculation of Global Intangible Low-Taxed Income (“GILTI”)
By Anthony Diosdi The IRS Form 8892 is used to calculate a controlled foreign corporation (“CFC”) global intangible low-taxed income” or GILTI. Form 8892 consists of Parts I and II. A U.S. shareholder that owns, within the meaning of Section 958(a), stock in one or more CFCs must attach a Form 8892 to a Form 5471. This article will go line by line through the Form 8992 to determine how a GILTI inclusion is determined. This article is based on the Internal Revenue Service (“IRS”) instructions to Form 8992. CFC shareholders are also required to attach either separate Schedule A or separate Schedule B, depending upon whether the shareholder of the CFC is a member of a U.S. consolidated group. Part 1. Net Controlled Foreign Corporation (CFC) Tested IncomeIf the…