8992 U.S Shareholder Calculation of Global Intangible Low‐Tax

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Form

8992

(December 2018)
Department of the Treasury
Internal Revenue Service

U.S. Shareholder Calculation of Global Intangible
Low-Taxed Income (GILTI)
▶

OMB No. 1545-0123

Attachment
Sequence No. 992

Go to www.irs.gov/Form8992 for instructions and the latest information.
A Identifying number

Name of person filing this return

DRAFT AS OF
September 25, 2018
DO NOT FILE
B Identifying number

Name of U.S. shareholder

Part I

1
2
3

Net Controlled Foreign Corporation (CFC) Tested Income

Sum of Pro Rata Share of Net Tested Income (total from Form 8992–Schedule A, column (e), line 1) .
Sum of Pro Rata Share of Net Tested Loss (total from Form 8992–Schedule A, column (f), line 1) . .
Net CFC Tested Income (combine line 1 and line 2) (if zero or negative, stop here) . . . . . . .

Part II

1
2
3

(

)

Calculation of Global Intangible Low-Taxed Income (GILTI)

1
2a

Net CFC Tested Income (from Part I, line 3) . . . . . . . . . . . . . . .
Pro Rata Share of QBAI multiplied by 10% (total from Form 8992–Schedule A,
2a
column (g), line 1) . . . . . . . . . . . . . . . . . . . .
b Specified Interest Expense (total from Form 8992–Schedule A, column (i),
line 1) . . . . . . . . . . . . . . . . . . . . . . . .
2b
c Net Deemed Tangible Income Return (DTIR) (subtract line 2b from line 2a) (if zero or
here) . . . . . . . . . . . . . . . . . . . . . . . . . . .
3
GILTI (subtract line 2c from line 1) (see instructions) . . . . . . . . . . . .

For Paperwork Reduction Act Notice, see separate instructions.

.

.

.

.

.

less, enter -0. . . . .
. . . . .

Cat. No. 37816Y

1

2c
3

Form 8992 (12-2018)

Form 8992 (12-2018)

DRAFT AS OF
September 25, 2018
DO NOT FILE

Page 2

Schedule A Schedule A for U.S. Shareholder Calculation of Global Intangible Low-Taxed Income (GILTI)
Name of person filing this return

A Identifying number

Name of U.S. shareholder

B Identifying number

Calculations for Net Tested Income
(see instructions)

(a)
Name of CFC

(b)
EIN or
Reference ID

(c)
Tested Income

(e)
Pro Rata Share
of Tested
Income

(d)
Tested Loss

(
(
(
(
(
(
(
(
(
(
(
1. Totals (see instructions) . . . . . . .
Totals on line 1 should include the totals from any continuation sheets.

)
)
)
)
)
)
)
)
)
)
)

(g)
Pro Rata Share
of Qualified
Business Asset
Investment
(QBAI) Multiplied
by 10% (0.10)

(f)
Pro Rata Share of
(Tested Loss)

(
(
(
(
(
(
(
(
(
(
(

GILTI Allocated to Tested
Income CFCs

(h)
Pro Rata
Share
of Interest
Expense

(i)
Specified
Interest
Expense

(k)
(j)
GILTI Allocated to
GILTI Allocation Tested Income
Ratio (Divide
CFCs (Multiply
Col. (e) by
Form 8992,
Col. (e), Line 1
Part II, Line 3,
Total)
by Col. (j))
(see instructions)

)
)
)
)
)
)
)
)
)
)
)

Form 8992 (12-2018)

Form 8992 (12-2018)

DRAFT AS OF
September 25, 2018
DO NOT FILE

Page 3

Schedule A—Continuation Sheet Use only if you need additional space
Name of person filing this return

A Identifying number

Name of U.S. shareholder

B Identifying number

Calculations for Net Tested Income
(see instructions)

(a)
Name of CFC

(b)
EIN or
Reference ID

(c)
Tested Income

(d)
Tested Loss

(e)
Pro Rata Share
of Tested
Income

(
)
(
)
(
)
(
)
(
)
(
)
(
)
(
)
(
)
(
)
(
)
1. Totals (see instructions) (continued) . . .
Totals of columns (c) through (k) should be included on line 1 Totals on page 2.

(g)
Pro Rata Share
of Qualified
Business Asset
Investment
(QBAI) Multiplied
by 10% (0.10)

(f)
Pro Rata Share of
(Tested Loss)

(
(
(
(
(
(
(
(
(
(
(

GILTI Allocated to Tested
Income CFCs

(h)
Pro Rata
Share
of Interest
Expense

(i)
Specified
Interest
Expense

(k)
(j)
GILTI Allocated to
GILTI Allocation Tested Income
Ratio (Divide
CFCs (Multiply
Col. (e) by
Form 8992,
Col. (e), Line 1
Part II, Line 3,
Total)
by Col. (j))
(see instructions)

)
)
)
)
)
)
)
)
)
)
)

Form 8992 (12-2018)

Form 8992 (12-2018)

DRAFT AS OF
September 25, 2018
DO NOT FILE

Page 4

Schedule A—Continuation Sheet Use only if you need additional space
Name of person filing this return

A Identifying number

Name of U.S. shareholder

B Identifying number

Calculations for Net Tested Income
(see instructions)

(a)
Name of CFC

(b)
EIN or
Reference ID

(c)
Tested Income

(d)
Tested Loss

(e)
Pro Rata Share
of Tested
Income

(
)
(
)
(
)
(
)
(
)
(
)
(
)
(
)
(
)
(
)
(
)
1. Totals (see instructions) (continued) . . .
Totals of columns (c) through (k) should be included on line 1 Totals on page 2.

(g)
Pro Rata Share
of Qualified
Business Asset
Investment
(QBAI) Multiplied
by 10% (0.10)

(f)
Pro Rata Share of
(Tested Loss)

(
(
(
(
(
(
(
(
(
(
(

GILTI Allocated to Tested
Income CFCs

(h)
Pro Rata
Share
of Interest
Expense

(i)
Specified
Interest
Expense

(k)
(j)
GILTI Allocated to
GILTI Allocation Tested Income
Ratio (Divide
CFCs (Multiply
Col. (e) by
Form 8992,
Col. (e), Line 1
Part II, Line 3,
Total)
by Col. (j))
(see instructions)

)
)
)
)
)
)
)
)
)
)
)

Form 8992 (12-2018)