Alert: IRS guidance clarifies GILTI calculation
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.