Skip to Content

Alert: IRS guidance clarifies GILTI calculation

October 1, 2018 Article 5 min read
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

Business professional discussing state and local tax updates while standing in a lobby.
March 27, 2023

State and local tax advisor: March 2023

Article 17 min read
Silhouette of business professional using their computer.
March 24, 2023

New tax credits make energy-efficient home and vehicle upgrades more affordable

Article 11 min read
Group of business professionals talking outside.
Mar. 21, 2023

Taxation mismatches: What anti-tax avoidance directive II (ATAD2) means for taxpayers

Webinar 1 hour watch