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

Two tax professionals standing on steps discussing cost segregation.
June 6, 2024

Real estate company saves $2.3 million in taxes using cost segregation

Case Study 2 min read
Aerial view of Washington D.C. at dusk.
June 6, 2024

4 ways to monetize Inflation Reduction Act tax credits

Article 7 min read
Birds flying above water in front of a U.S. government building.
May 29, 2024

State and local tax advisor: May 2024

Article 30 min read