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).

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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.

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