The IRS has issued proposed regulations on Section 951A global intangible low-taxed income (GILTI) provisions. Under the rules in the 2017 Tax Cuts and Jobs Act (TCJA), a U.S. person who owns at least 10 percent of the value or voting rights in one or more controlled foreign corporations (CFC) will be required to include its GILTI as currently taxable income, regardless of whether any amount is distributed to the shareholder.
The IRS has released some draft forms and instructions for reporting GILTI:
- Form 8992, S. Shareholder Calculation of GILTI https://www.irs.gov/pub/irs-dft/f8992--dft.pdf
- Instructions for Form 8992 https://www.irs.gov/pub/irs-dft/i8992--dft.pdf
- Form 8993, Section 250 Deduction for Foreign-Derived Intangible Income (FDII) and GILTI https://www.irs.gov/pub/irs-dft/f8993--dft.pdf (Form 8993 instructions have not been released.)