Skip to Content

Alert: IRS guidance clarifies GILTI calculation

October 1, 2018 Article 5 min read
Authors:
Kellie Becker Randall Janiczek Irina Rangelova Michael Monaghan
IRS releases guidance on calculating global intangible low-taxed income (GILTI).

Image of woman standing in a city center

The IRS has released proposed regulations to help affected taxpayers calculate the amount of global intangible low-taxed income (GILTI) generated by controlled foreign corporations (CFCs). The guidance is intended to help affected taxpayers:

  • Calculate the amount of global intangible low-taxed income generated by a controlled foreign corporation.
  • Distribute that amount accurately among shareholders.

These proposed regulations help U.S. taxpayers who own CFCs calculate a GILTI inclusion amount based on the aggregate activities of all subsidiaries. This will add some new complexity to tax returns for 2018 and beyond.

Related Thinking

View of government building with American flag.
December 7, 2023

Inflation Reduction Act: Tax incentives for energy-efficient buildings

Webinar 1 hour watch
Business professionals discussing regulations on tax credits.
December 6, 2023

Navigating the tax consequences for nonprofit and for-profit healthcare system affiliations

Webinar 1 hour watch
Close-up view of the corner of a building.
December 1, 2023

Pass-through entity tax deductions may help restore deductibility of state taxes

Article 3 min read