Global Intangible Low Taxed Income (GILTI)

Definitions

Controlled Foreign Corporation (CFC):
International Filing Type is Foreign Entity.
In the
Binder Properties
tab:
International, Foreign Entity Type is Controlled Foreign Corporation.
International Entity Type is Foreign Entity.
GILTI Tested Unit:
A CFC, or a division of a CFC, if in the
Binder Properties
tab International, GILTI Tested Unit is selected.
U.S. Shareholder:
International Filing Type is Foreign Tax Credit.
In the Organization Chart, the entity directly owns a foreign entity.
Only shareholders with an ownership of more than 10% are automatically included in the GILTI calculations.
To review the Organization Chart, in the top consolidation under Foreign Tax Credit in International Diagram:
For Organization or Intercompany, select
Ownership
. For Layout, select
Tree
.
Select
Load
.
U.S. Shareholders are Domestic Corporations above the highest
Foreign Corporation(s)
.
Ownership percentages next to the lines connecting entities are multiplied through a maximum of Seven (7) Foreign Corporation levels.
Updates are entered in the top consolidation in
Binder Properties
tab International Members by selecting
Parent(s)
or
Add Ownership
, then selecting the
Parent
and entering the Ownership Percentage, summing to 100.000000.
If the U.S. Shareholder owns less than 10% of the CFC, in the top consolidation in CFC Overrides under Foreign Tax Credit.
For Foreign Entity, select the
CFC
, then in column
Deemed Paid Credit Test Override
select
Pass Ownership Test for Deemed Paid Credit Purpose
.
If the column
Parent Type
is
US
or
US/DO
, in column
U.S. Shareholder Override
, select
Treat this entity as a U.S. Shareholder
, then
Save.
When changes are made to the ownership, in the top consolidation under Foreign Tax Credit in the
International Computes
tab
E&P, LT, SUBF
, select
all entities
.
Under
Select Computes
, select
E&P, Look Through
(optional), and
Subpart F
, then
Compute.

GILTI calculation

In the top consolidation in
GILTI (Global Intangible Low Taxed Income)
Foreign Tax Credit
FTC Defaults
, select
Transfer Subpart F Results to GILTI Workpaper
and
GILTI High Tax Exception
.
In
Foreign Entity Section 163(j) Calculation
, select
Transfer to 163(j) Workpaper
,
163(j) Adjustment – GILTI Computations
, and
163(j) Adjustment – Subpart F Computations
.
In the CFC under Foreign Entity in the
GILTI (Global Intangible Low Taxed Income
tab, QBAI in Functional Currency for 1st Quarter, 2nd Quarter, 3rd Quarter, and 4th Quarter, populate Bases in Specified Tangible Property, Accumulated Tax Depreciation (Enter as a Negative) (optional), and Other Adjustments (optional). Select
Save
.
In the
Tested Item Sourcing and Translation
tab for 8 Qualified Business Asset Investment (QBAI), enter the Passive Income and General Limitation Income amounts. Select
Save
.
In the
High Tax Exception Adjustments
tab for Entity, select the
CFC
or
Division
.
For Disregarded Payments (FC), Other Deductions Adjustment (FC), Interest Expense Adjustment (FC), and Foreign Income Taxes Adjustment (FC), populate the Passive Income and General Limitation Income, with positive amounts decreasing Gross Income, or increasing Other Deductions, Interest Expense and Foreign Income Taxes, and negative amounts increasing Gross Income or decreasing Other Deductions, Interest Expense and Foreign Income Taxes.
In the top consolidation under Foreign Tax Credit in the
International Compute
tab
E&P, LT, SUBF
, select
all entities, E&P, Look Through
,
Subpart F
, and
Transfer to US5471, US8865 and US8858 (International Organization Chart)
, then
Compute
.
In the top consolidation under
Report Set
Select Entities
International Reports
Foreign Tax Credit
, select
Subpart F
,
all entities
, then
Save Entities
.
Review the reports at
GILTI (Global Intangible Low Taxed Income)
Select Reports Subpart F Reports
.

Section 951A GILTI High Tax Exception
populates with:
The country, group, and amounts for each GILTI Tested Unit for Passive Income and General Limitation Income.
Subtotaled by Tested Unit.
Totaled by the CFC with the calculated amounts and adjustments that transfer to Foreign Entity in
GILTI (Global Intangible Low Taxed Income
tabs
Tested Item Sourcing and Translation
and
High Tax Exception Adjustments
.
Verify for each division, tested unit, and the CFC:
Tested Unit Country Group
Country of Operation
Tested Unit Status
Subpart F Income
High Tax Exception Income
Related Party Dividends
Disregarded Payments Adjustments
Weighted Average Exchange Rate
Total Foreign Income Taxes Paid (U.S. Dollar)
Effective Tax Rate
Tentative Tested Income (FC) Not Excepted
Tentative Tested Income (FC) Qualified for Exception
GILTI Tested Item Sourcing and Translation Import Report populates with the amounts under Foreign Entity in the
GILTI (Global Intangible Low Taxed Income
tab Tested Item Sourcing and Translation for transfer to
Organizer
Foreign Information
Foreign Corporation
Foreign Corporation
under [name of 5471]
in
Schedule I-1
tabs
Passive Category Income
and
General Category Income
.
Consolidated Group GILTI (Global Intangible Low Taxed Income) Tested Items populates with the amounts for each CFC multiplied by the total U.S. shareholder Ownership Percentage summed to the consolidated totals or Tested Income, Test Loss, Qualified Business Asset Investment (QBAI), Tested Interest Income, Tested Interest Expense, and Specified Interest Expense.
Verify the Last Subpart F Calculation is the same date and time for all CFCs.
EIN or Reference ID is populated for all CFCs.
Under U.S. Shareholder Ownership, Consolidated Group U.S. Shareholder Ownership is greater than 50% and the correct percentage.
Under Consolidated Group Tested Income (Loss), whether the amount of Consolidated Group Tested Income or Consolidated Group Tested (Loss) in column Total is greater.
Under Consolidated Group Qualified Business Asset Investment (QBAI), the amount of Consolidated Group QBAI in column Total.
Under Consolidated Group Specified Interest Expense, the amount of Specified Interest Expense in column Total.
Form 8992 Schedule A – U.S. Shareholder CFC Detail Report populates with the back allocation to each U.S. shareholder.
Each CFC is owned by each U.S. shareholder for transfer to Shareholder Calculation of GILTI in Organizer under Foreign Information in the U.S. shareholders.
For Divisional Consolidation U.S. shareholders, in
Binder Properties
tab
Members
column
Action
, the division with
Parent Binder
selected.
Verify CFC Name is 45 characters or less, and Last Subpart F Calculation is the same for all CFCs.
U.S. Shareholder GILTI Deemed Paid Tax Report populates with the allocation of Tested Foreign Income Taxes (Total) to Passive Income and GILTI Income.
The calculation of Section 78 Gross Up, and Tax Deemed Paid for each U.S. Shareholder for transfer to
Organizer
Foreign Information
Intl Foreign Tax Credit
Schedules C, D, E
PAS-951A
and
951A-951A
under
Schedule D
under each
CFC
in
Schedule D
.