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GILTI Tax Compliance

A U.S. shareholder of one or more Controlled Foreign Corporation (CFC) shall include in gross income its “global intangible low-taxed income” (GILTI) in a manner similar to subpart F income. The effect of this rule is to subject a U.S. shareholder to a tax on the combined net income of its CFCs that (1) is not otherwise taxed un the U.S. on a current basis and (2) exceeds a fixed routine return on the CFC’S associated business assets.

Some terms you need to understand in order to calculate the GILTI.

  • Tested income
  • Tested loss
  • Shareholder’s net deemed tangible income return
  • Net CFC tested income
  • QBAI
  • Tested foreign income taxes

We are frequently approached with client requests to assist with GILTI Tax Compliance. Some common questions are:

  • Does GILTI apply to me?
  • I have several lines of business – how do I apply GILTI tax to only one portion of my business?
  • Is GILTI shown on my form 5471? What other forms do I need to complete?
  • What is the percentage tax on GILTI?
  • I am thinking of creating a foreign subsidiary. What can I do to make sure that GILTI does not apply to me?
  • I just realized that I have been filing my tax incorrectly last couple years. What can I do to correct the situation? How can I avoid penalties for non-compliance?

For these questions and any others regarding GILTI Tax, please contact us below and we will respond within hours.

Need some help? Please fill out the form below and one of our specialists will get back to you immediately.


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