Global Intangible Low-Taxed Income and Form 8992 (Currently Unavailable)
Author: Robert J. Misey
| CPE Credit: |
2 hours for CPAs
2 hours Federal Tax Related for EAs and OTRPs |
Owners of foreign subsidiaries previously worried only about Subpart F income, but the 2017 Act created a new anti-deferral regime – Global Intangible Low-Taxed Income (“GILTI”). Very simply, GILTI forces the U.S. owner to report the income of the foreign subsidiary that is in excess of 10% of the foreign subsidiary’s depreciable assets. However, it is rarely that simple and the IRS has promulgated 80 pages of regulations (with a 70-page preamble) as guidance.
Publication Date: May 2019
Designed For
Tax practitioners in both public accounting and in industry engaging in planning or conducting compliance for foreign subsidiaries.
Topics Covered
- Determining GILTI based on Tested Income and Qualified Business Assets Investment
- Tested Income and the various exclusions
- Qualified Business Assets Investment
- Completion of a sample form 8992
Learning Objectives
- Identify the policy of GILTI
- Recognize and apply the calculation of GILTI and the 50% deduction
- Identify the foreign tax credit for GILTI
- Recognize how to plan for tax-efficient foreign operations
- Identify the GILTI Pro Rata Inclusion calculation
- Recognize how the calculation of GILTI is similary to what Subart in that it starts at the Controlled Foreign Income level
- Describe how GILTI is defined
- Recognize what is excluded from Net CFC Tested Income as income of a CFC
- Identify an important planning aspect of GILTI
- Describe the percentage of QBAI is used as an adjustment against Net Tested Income for purposes of the GILTI Pro Rata Inclusion
- Recognize which type of interest expense is deducted from Net Tested Income when calculating the GILTI Pro Rata Inclusion
- Identify the excess of net CFC tested income over net deemed tangible income return
- Identify specified tangible property used in the production of tested income
- Recognize which election is made to ensure an individual taxpayer is not subject to a higher rate of tax on the earnings of a directly-owned foreign corporation than if he or she had owned it through a U.S. corporation
Level
Basic
Instructional Method
Self-Study
NASBA Field of Study
Taxes (2 hours)
Program Prerequisites
None
Advance Preparation
None
