8992 Instructions for Form 8992

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Instructions for Form 8992

Department of the Treasury
Internal Revenue Service

(Rev. December 2022)

U.S. Shareholder Calculation of Global Intangible Low-Taxed Income (GILTI)
Section references are to the Internal Revenue
Code unless otherwise noted.

and Global Intangible Low-Taxed Income
(GILTI), and its instructions.

Future Developments

Domestic partnerships. Domestic
partnerships are no longer required to
complete Form 8992 or Schedule A (Form
8992). Instead, domestic partnerships
must complete Schedule K-2 (Form 1065),
Part VI, and Schedule K-3 (Form 1065),
Part VI.

U.S. shareholder. A U.S. shareholder of
a foreign corporation is a U.S. person who
owns (directly, indirectly, or constructively,
within the meaning of section 958) 10% or
more of the total combined voting power
of all the classes of voting stock of the
foreign corporation or 10% or more of the
total value of shares of all classes of stock
of the foreign corporation.

DRAFT AS OF
October 31, 2022

For the latest information about
developments related to Form 8992 and
its instructions, such as legislation
enacted after they were published, go to
IRS.gov/Form8992.

Additional guidance may be issued
subsequent to these instructions. Please
review any additional information on
IRS.gov/Form8992 prior to completing
Form 8992.

What’s New
Form 8992. Part II, line 5, of the form
shows the U.S. shareholder’s GILTI
inclusion amount. Line 5 of the form
instructs filers to subtract line 4 from line 1.
The following sentence has been added at
the end of line 5 of the form: “If zero or
less, enter -0-.” This clarification is
consistent with the “Note” that was already
present in the specific instructions for
Form 8992, Part II, line 5. It has now been
added to the form to make the form more
intuitive.
Schedule A and Schedule B. With
respect to Schedule A (Form 8992),
column (b), and Schedule B (Form 8992),
Part I, column (b), those columns request
an employer identification number (EIN) or
reference ID number with respect to
Controlled Foreign Corporations (CFCs).
With respect to each CFC, if the CFC has
an EIN, the taxpayer must enter that EIN in
column (b). Taxpayers will no longer have
the option to enter “APPLIED FOR” in
column (b) in lieu of an EIN. If the CFC
does not have an EIN, the taxpayer must
enter a reference ID number that uniquely
identifies the CFC. Taxpayers will no
longer have the option to enter
“FOREIGNUS” in column (b) in lieu of a
reference ID number. Also, if the taxpayer
has filed or will be filing a Form 5471 with
respect to the CFC, the reference ID
number for that CFC must be the same on
Form 5471 and column (b) of either
Schedule A (Form 8992) or Schedule B
(Form 8992), Part I, as applicable.

Reminders
Form 8993 deduction. If you are eligible
for a deduction under section 250 for your
GILTI inclusion, please see Form 8993,
Section 250 Deduction for
Foreign-Derived Intangible Income (FDII)
Oct 27, 2022

General Instructions

Purpose of Form

Public Law 115-97 (Tax Cuts and Jobs Act
of 2017) enacted section 951A, which
requires U.S. shareholders who own
(within the meaning of section 958(a)) a
CFC to include GILTI in gross income.
Form 8992 is used by a U.S. shareholder
to calculate the amount of the GILTI
inclusion and to report related information.
Generally, Schedule A (Form 8992) is also
completed and attached to Form 8992.
However, if the U.S. shareholder is a
member of a U.S. consolidated group,
Schedule B (Form 8992) is completed and
attached to Form 8992 instead.

Who Must File

A U.S. shareholder (including a partner of
a domestic partnership) that owns, within
the meaning of section 958(a), stock in
one or more CFCs. See Regulations
sections 1.951A-1(e) and 1.6038-5(a).

Members of a U.S. consolidated group.
While each U.S. shareholder that is a
member of a U.S. consolidated group is
required to complete a separate Form
8992, these Forms 8992 should not be
filed with the consolidated return. Instead,
a single consolidated Form 8992 must be
completed and filed with the consolidated
group's return. See the instructions for
Schedule B, later, for information
regarding the steps necessary to complete
Schedule B (Form 8992) and Form 8992.
S corporations that elect entity treatment. An S corporation that elects to be
treated as an entity under Notice 2020-69
must file Form 8992. For additional
information, see the Instructions for Form
1120-S.
CFC. A CFC is generally a foreign
corporation of which more than 50% of the
total combined voting power or value is
owned directly, indirectly, or constructively
(within the meaning of section 958) by
U.S. shareholders.

Cat. No. 71351C

When and Where To File

In general, attach Form 8992 and
Schedule A (Form 8992) to your income
tax return (or exempt organization return,
as applicable) and file both by the due
date (including extensions) for that return.
Members of a U.S. consolidated group.
Attach Schedule B (Form 8992) and one
consolidated Form 8992 to the U.S.
consolidated group's income tax return
and file both by the due date (including
extensions) for that return. See the
instructions for Schedule B, later, for
information regarding the steps necessary
to complete Schedule B (Form 8992) and
Form 8992.

S corporations that elect entity treatment. An S corporation that elects to be
treated as an entity under Notice 2020-69
must complete Form 8992 and
Schedule A (Form 8992) and attach them
to its Form 1120-S by the due date
(including extensions) for that return. For
additional information, see the Instructions
for Form 1120-S.

Computer-Generated Form
8992

Generally, all computer-generated forms
must receive prior approval from the IRS
and are subject to an annual review.
However, see the exception below.
Requests for approval may be submitted
electronically to [email protected],
or requests may be mailed to: Internal
Revenue Service, Attention: Substitute
Forms Program, SE:W:CAR:MP:P:TP,
1111 Constitution Ave. NW, Room 6554,
Washington, DC 20224.
Be sure to attach the approval
letter to Form 8992. However, if
CAUTION the computer-generated form is
identical to the IRS-prescribed form, it
does not need to go through the approval
process, and an attachment is not
necessary.

!

Every year, the IRS issues a revenue
procedure to provide guidance for filers of
computer-generated forms. In addition,

every year, the IRS issues Pub. 1167,
General Rules and Specifications for
Substitute Forms and Schedules, which
reprints the most recent applicable
revenue procedure. Pub. 1167 is available
at IRS.gov/Pub1167.

Corrections to Form 8992

If you file a Form 8992 that you later
determine is incomplete or incorrect, file a
corrected Form 8992 with an amended tax
return, using the amended return
instructions for the return with which you
originally filed Form 8992. Write
“Corrected” at the top of Form 8992 and
attach a statement identifying the
changes.

parent as the person filing the return and
enter its EIN in item A.

Item B. Identifying Number

If the name of the U.S. shareholder of the
CFC(s) reported on this Form 8992 is
different from the name of the person filing
this return, enter the U.S. shareholder’s
identifying number. In the case of a U.S.
consolidated group, leave the name of the
U.S. shareholder and item B blank.

inclusion amount, if any, and to determine
the amount of the U.S. shareholder’s
GILTI inclusion amount, if any, allocated to
each of its CFCs. If a U.S. shareholder
does not file a Schedule I-1 (Form 5471)
for a CFC that is part of its GILTI
computation, for instance, due to an
exception for multiple filers of the same
information, the U.S. shareholder will still
need to provide amounts with respect to
each CFC as if the U.S. shareholder filed
Schedule I-1 (Form 5471) for that CFC.

DRAFT AS OF
October 31, 2022

Treaty-Based Return
Positions

You are generally required to file Form
8833, Treaty-Based Return Position
Disclosure Under Section 6114 or
7701(b), to disclose a return position that
any treaty of the United States (such as an
income tax treaty, an estate and gift tax
treaty, or a friendship, commerce, and
navigation treaty):
• Overrides or modifies any provision of
the Internal Revenue Code; and
• Causes, or potentially causes, a
reduction of any tax incurred at any time.

Part I

If the U.S. shareholder is not a member of
a U.S. consolidated group, to figure the
amounts to enter on lines 1 and 2, first
complete Schedule A (Form 8992),
columns (a) through (f). See the specific
instructions for Schedule A, later. Then,
follow the applicable instructions on the
face of Form 8992, Part I, lines 1 through
3, to determine the amounts to enter on
each of those lines.

If the amount on line 3 is greater than
zero, complete Schedule A (Form 8992),
columns (g) through (l). If the amount on
line 3 is zero or negative, do not complete
Part II of Form 8992 or Schedule A (Form
8992), columns (g) through (l). Include
Form 8992 and Schedule A (Form 8992)
with your return.

Specific Instructions

If the U.S. shareholder is a member of
a U.S. consolidated group, see Steps
necessary to complete Schedule B (Form
8992) and Form 8992, later.

Form 8992

Part II

See Form 8833 for exceptions.

Use Form 8992 to compute the U.S.
shareholder’s GILTI inclusion amount.
Complete Form 8992 as follows.

• If the U.S. shareholder is not a member

of a U.S. consolidated group, use
Schedule A (Form 8992), to determine the
amounts to enter on Form 8992, Part l.
• If the U.S. shareholder is a member of a
U.S. consolidated group, use Schedule B
(Form 8992) to determine the amounts to
enter on Form 8992, Part l.
Important: If completing Schedule B
(Form 8992), see Steps necessary to
complete Schedule B (Form 8992) and
Form 8992, later.

Name Change

If the name of the person filing the return
changed within the past 3 years, include
the prior name in parentheses after the
current name.

Item A. Identifying Number

The identifying number of an individual is
the individual’s social security number
(SSN). The identifying number of all others
is their EIN. In the case of a U.S.
consolidated group, list the common

For each line on Form 8992, Part II, follow
the instructions on the face of the form to
determine the amount to enter on that line.
Note. If the amount on line 4 is greater
than the amount on line 1, enter zero on
line 5.
For a corporate shareholder, enter the
Part II, line 5, result on the appropriate line
of Form 1120, Schedule C, or on the
comparable line of other corporate
returns.
For an individual shareholder, enter the
Part II, line 5, result on the appropriate
“other income” line of Schedule 1 (Form
1040), or on the comparable line of other
noncorporate tax returns.

Schedule A

In the case of a U.S. shareholder that is
not a member of a U.S. consolidated
group, the U.S. shareholder files
Schedule A (Form 8992), to report its pro
rata share of amounts for each CFC (the
tax year of which ends with or within the
shareholder’s tax year) from each CFC’s
Schedule I-1 (Form 5471), Information for
Global Intangible Low-Taxed Income, to
determine the U.S. shareholder’s GILTI
-2-

Due to space limitations, if you
need to list more CFCs than fit on
CAUTION one Schedule A (Form 8992),
attach Schedule A—Continuation Sheet(s)
to continue listing the CFCs and their
respective information. Do not write “See
attached” in the section and attach
additional sheets.

!

Column (a). Enter the name of each
CFC. If the name of any of the CFCs being
reported on Schedule A (Form 8992)
changed within the past 3 years, include
the prior name(s) in parentheses after the
current name.
Column (b). With respect to each CFC
reported on Schedule A, if the CFC has an
EIN, you must enter that EIN in column
(b). Do not enter “APPLIED FOR” in
column (b) in lieu of an EIN. If the CFC
does not have an EIN, you must enter a
reference ID number that uniquely
identifies the CFC. Do not enter
“FOREIGNUS” in column (b) in lieu of a
reference ID number. For more
information regarding reference ID
numbers, see the instructions for Form
5471, item 1b(2), Reference ID Number.
Note that if a U.S. shareholder is required
to file Schedule A (Form 8992) or
Schedule B (Form 8992) with respect to a
CFC, the reference ID number on Form
5471 and the reference ID number used
on Schedule A (Form 8992) or Schedule B
(Form 8992) for that CFC must be the
same.
Column (c). Enter the U.S. dollar amount
of tested income, if any, from line 6 of
Schedule I-1 (Form 5471) for each CFC
listed in column (a).
Column (d). Enter the U.S. dollar amount
of tested loss, if any, from line 6 of
Schedule I-1 (Form 5471) for each CFC
listed in column (a).
Column (e). Enter your pro rata share (as
determined under Regulations section
1.951A-1(d)(2)) of the tested income listed
in column (c).
Column (f). Enter your pro rata share (as
determined under Regulations section
1.951A-1(d)(4)) of the tested loss listed in
column (d).
Important: See the instructions for
Form 8992, Part I, earlier, to determine if

Instructions for Form 8992 (Rev. 12-2022)

you are required to complete columns (g)
through (l).
Column (g). Enter your pro rata share (as
determined under Regulations section
1.951A-1(d)(3)) of the U.S. dollar amount
of QBAI from line 8 of Schedule I-1 (Form
5471) for each tested income CFC.

8992) the totals for columns (g) through (l)
for Schedule A (Form 8992) and any
Schedule A—Continuation Sheets.

Schedule B
Purpose of schedule. Use Schedule B
to report amounts used in determining the
GILTI inclusion amount of each member of
a consolidated group that is a U.S.
shareholder of any CFC. In doing so,
apply the rules of section 951A to each
member in accordance with Regulations
section 1.1502-51 as follows.
Use Part I to report relevant amounts
from Schedule I-1 (Form 5471) for each
CFC owned (within the meaning of section
958(a)) by any member of the U.S.
consolidated group as well as the pro rata
shares of such amounts for each member.
Use Part II to report the calculations
necessary to determine the amounts that
will be carried over to the Form 8992 of
each member that is a U.S. shareholder in
order to determine that member’s GILTI
inclusion amount. See How to complete
and file Schedule B (Form 8992) and
Form 8992 below.
Complete only one Schedule B (Form
8992) for the U.S. consolidated group, and
provide a copy to each member of the
group.

b. Enter the totals for columns (e)
through (h) on line 1 of those columns. In
doing so, please note that the total
amounts for Part I, columns (e) and (f)
should not reflect items from any CFC
more than once, even if the CFC is listed
more than once.
c. If the line 1 total for Part I, column
(h), equals or exceeds the line 1 total for
Part I, column (g), do not complete the
remainder of Schedule B. Also, do not
complete the remainder of step 1 or any
portion of step 2. Proceed to step 3.
d. If the line 1 total for Part I, column
(g), exceeds the line 1 total for Part I,
column (h), complete Part I, columns (i)
through (n), using the instructions
provided below. Enter the totals for
columns (i) through (n) on line 1 of those
columns. In doing so, please note that the
total amounts for Part I, columns (k) and
(m), should not reflect items from any CFC
more than once, even if the CFC is listed
more than once.
e. Skip Part I, columns (o) and (p), for
now. Do not complete Part I, columns (o)
and (p), unless instructed to do so later.
f. Complete all columns of
Schedule B, Part II (columns (a) through
(m)), using the instructions provided
below.
2. Complete a separate Form 8992 for
each U.S. shareholder listed in
Schedule B (Form 8992), Part II, using the
instructions provided on the face of Form
8992, to determine each U.S.
shareholder’s GILTI inclusion amount.
3. Complete a consolidated Form
8992, as follows.
a. If the Schedule B (Form 8992),
line 1, total for Part I, column (h), equals or
exceeds the line 1 total for Part I, column
(g): Enter the amount from Schedule B
(Form 8992), Part I, line 1, column (g), on
Form 8992, Part I, line 1. Enter the amount
from Schedule B, Part I, line 1, column (h),
on Form 8992, Part I, line 2. Combine the
amounts shown on Form 8992, Part I,
lines 1 and 2, and enter the result on Form
8992, Part I, line 3. Do not complete the
remainder of Form 8992. This is the
consolidated Form 8992 that will be filed
with the U.S. consolidated group’s income
tax return. Do not complete the remainder
of the steps listed below.
b. If the Schedule B (Form 8992),
line 1, total for Part I, column (h), is less
than the line 1 total for Part I, column (g):
For each line of the Form 8992, aggregate
the amounts from the corresponding line
of all Forms 8992 completed for each U.S.
shareholder from step 2, and enter the
total on the corresponding line of the
consolidated Form 8992. File the
consolidated Form 8992 with the U.S.
consolidated group’s income tax return.

DRAFT AS OF
October 31, 2022

Note. If you have a tested loss for a
particular CFC, no entry should be made
for that CFC in this column. See
Regulations section 1.951A-3(b).

Column (h). Enter your pro rata share (as
determined under Regulations section
1.951A-1(d)(3)) of the tested loss QBAI
amount of any tested loss CFC. The
tested loss QBAI amount of a tested loss
CFC is the amount reported on
Schedule I-1 (Form 5471), line 9c, that the
tested loss CFC would have had if it were
instead a tested income CFC. See
Regulations sections 1.951A-4(b)(1)(i)
and 1.951A-4(b)(1)(iv), and example 5 of
Regulations section 1.951A-4(c)(5).
Column (i). Enter your pro rata share (as
determined under Regulations section
1.951A-1(d)(6)) of the amount of tested
interest income from Schedule I-1 (Form
5471), line 10c, for each CFC.
Column (j). Enter your pro rata share (as
determined under Regulations section
1.951A-1(d)(5)) of tested interest expense
from Schedule l-1 (Form 5471), line 9d.
Column (k). Before completing column
(k), enter the totals (including amounts
from any Schedule A—Continuation
Sheet(s)) of columns (c) through (j) on
line 1 for each column and complete Form
8992, Parts I and II. Then, for each CFC
with an amount in column (e), divide that
amount by the total on line 1, column (e).
Enter the result here to four decimal
places. See section 951A(f)(2).
Column (l). For each CFC with an
amount in column (e), multiply the column
(k) ratio for that CFC by the Form 8992,
Part II, line 5, amount and enter the result
in column (l) in whole dollars only. This
information is used in completing
Schedule J (Form 5471), Accumulated
Earnings and Profits (E&P) of CFC, and
Schedule P (Form 5471), Previously
Taxed Earnings and Profits of U.S.
Shareholder of Certain Foreign
Corporations, for each CFC.

Line 1

On line 1 of the first completed page of
Schedule A (Form 8992), enter the totals
for columns (c) through (f) for Schedule A
(Form 8992) and any
Schedule A—Continuation Sheets. If the
amount on your Form 8992, Part I, line 3,
is positive, you are required to complete
Schedule A, columns (g) through (l), and
should also enter on line 1 of the first
completed page of Schedule A (Form
Instructions for Form 8992 (Rev. 12-2022)

Computer-generated Schedule B. A
computer-generated Schedule B can be
filed if it conforms to the IRS version of the
schedule. Expand Schedule B to properly
complete Parts I and II of the schedule if
the number of CFCs and/or U.S.
shareholders exceeds the number of lines
on Part I or Part II.
How to complete and file Schedule B
(Form 8992) and Form 8992. Complete
a single Schedule B (Form 8992) for all
members of the U.S. consolidated group
that are U.S. shareholders of a CFC.
Certain amounts from Schedule B (Form
8992) are carried over to the consolidated
group’s Form(s) 8992. A separate Form
8992 is completed for each member of the
consolidated group that is a U.S.
shareholder of a CFC. Additionally, a
consolidated Form 8992 is completed for
the consolidated group as a whole. The
Schedule B (Form 8992) and the
consolidated Form 8992 are filed with the
consolidated group’s income tax return.
Schedule B (Form 8992) and Form 8992
are completed using the following steps.
Steps necessary to complete Schedule B (Form 8992) and Form 8992.
1. Complete one Schedule B (Form
8992) for all members of the consolidated
group that are U.S. shareholders of a
CFC, as follows.
a. Complete Part I, columns (a)
through (h), using the instructions
provided below.
-3-

4. Complete Schedule B (Form 8992),
Part I, columns (o) and (p), using the
instructions provided below.
Note. Do not file the Forms 8992 that
were completed for each U.S.
shareholder. Instead, keep them for your
records so that they are available upon
request (for example, in the case of an
examination).

Note. For each CFC listed in column (a),
enter the column (e) amount on the
corresponding line of the U.S.
shareholder's applicable Form 1118,
Schedule D, Part I, column 6, for that CFC
(that is, the Form 1118 that is being
completed for passive category income or
general category income, as applicable).

the U.S. dollar amount of tested interest
expense, if any, from Schedule I-1 (Form
5471), line 9d.
Column (l), Pro rata share of tested interest expense. For each CFC listed in
column (a) and the U.S. shareholder listed
in column (c), enter the U.S. shareholder's
pro rata share (as determined under
Regulations section 1.951A-1(d)(5)) of the
CFC's tested interest expense listed in
column (k).

DRAFT AS OF
October 31, 2022

Instructions for Part I

Column (a), Name of CFC. In column
(a), list all CFCs, an interest in which is
owned (within the meaning of section
958(a)) by any member of the
consolidated group. If more than one
member of the consolidated group owns
(within the meaning of section 958(a)) an
interest in the same CFC, list the CFC on
multiple lines, using a separate line for
each member that owns an interest in the
CFC. Be sure to note the name and EIN of
the member that is a U.S. shareholder of
the CFC in columns (c) and (d). On each
line, enter the name of the CFC in column
(a). If the name of any of the CFCs being
reported on Schedule B (Form 8992)
changed within the past 3 years, include
the prior name(s) in parentheses after the
current name.

Column (b), EIN or reference ID number of CFC. With respect to each CFC
that must be reported on Schedule B, Part
I, if the CFC has an EIN, you must enter
that EIN in column (b). Do not enter
“APPLIED FOR” in column (b) in lieu of an
EIN. If the CFC does not have an EIN, you
must enter a reference ID number that
uniquely identifies the CFC. Do not enter
“FOREIGNUS” in column (b) in lieu of a
reference ID number. For more
information regarding reference ID
numbers, see the instructions for Form
5471, item 1b(2), Reference ID Number.
Note that if a U.S. shareholder is required
to file Schedule A (Form 8992) or
Schedule B (Form 8992) with respect to a
CFC, the reference ID number on Form
5471 and the reference ID number used
on Schedule A (Form 8992) or Schedule B
(Form 8992) for that CFC must be the
same.
Column (c), Name of U.S. shareholder.
For each CFC listed in column (a), enter in
column (c) the name of each U.S.
shareholder that owns (within the meaning
of section 958(a)) an interest in that CFC.
Column (d), EIN of U.S. shareholder.
For each U.S. shareholder listed in column
(c), enter the EIN of the U.S. shareholder.
Column (e), Tested income. For each
CFC listed in column (a), enter the U.S.
dollar amount of tested income, if any,
from line 6 of Schedule I-1 (Form 5471).

Column (f), Tested loss. For each CFC
listed in column (a), enter the U.S. dollar
amount of tested loss, if any, from line 6 of
Schedule I-1 (Form 5471).

Column (g), Pro rata share of tested income. For each CFC listed in column (a)
and the U.S. shareholder listed in column
(c), enter the U.S. shareholder's pro rata
share (as determined under Regulations
section 1.951A-1(d)(2)) of the CFC's
tested income listed in column (e).
Note. For each CFC listed in column (a),
enter the column (g) amount on the
corresponding line of the U.S.
shareholder's applicable Form 1118,
Schedule D, Part I, column 5, for that CFC
(that is, the Form 1118 that is being
completed for passive category income or
general category income, as applicable).

Column (h), Pro rata share of tested
loss. For each CFC listed in column (a)
and the U.S. shareholder listed in column
(c), enter the U.S. shareholder's pro rata
share (as determined under Regulations
section 1.951A-1(d)(4)) of the CFC's
tested loss listed in column (f).
Column (i), Pro rata share of QBAI. For
each tested income CFC listed in column
(a) and the U.S. shareholder listed in
column (c), enter the U.S. shareholder’s
pro rata share (as determined under
Regulations section 1.951A-1(d)(3)) of the
tested income CFC’s QBAI from line 8 of
that CFC’s Schedule I-1 (Form 5471).
Note. If you have a tested loss for a
particular CFC, no entry should be made
for that CFC in Part I, column (i). See
Regulations section 1.951A-3(b).
Column (j), Pro rata share of tested
loss QBAI amount. For each line where
there is a U.S. shareholder listed in
column (c) that owns an interest in a
tested loss CFC listed in column (a) of that
line, enter the U.S. shareholder’s pro rata
share (as determined under Regulations
section 1.951A-1(d)(3)) of the tested loss
QBAI amount of the CFC. The tested loss
QBAI amount of a tested loss CFC is an
amount equal to 10% of the QBAI from
Schedule I-1 (Form 5471), line 9c, that the
tested loss CFC would have had if it were
instead a tested income CFC. See
Regulations sections 1.951A-4(b)(1)(i)
and 1.951A-4(b)(1)(iv), and example 5 of
Regulations section 1.951A-4(c)(5).
Column (k), Tested interest expense.
For each CFC listed in column (a), enter
-4-

Column (m), Tested interest income.
For each CFC listed in column (a), enter
the U.S. dollar amount of tested interest
income, if any, from Schedule I-1 (Form
5471), line 10c.
Column (n), Pro rata share of tested interest income. For each CFC listed in
column (a) and the U.S. shareholder listed
in column (c), enter the U.S. shareholder's
pro rata share (as determined under
Regulations section 1.951A-1(d)(6)) of the
CFC's tested interest income listed in
column (m).
Columns (o) and (p). As explained in
Steps necessary to complete Schedule B
(Form 8992) and Form 8992, earlier,
Schedule B, Part I, columns (o) and (p),
are completed only after Form 8992 has
been completed. Also, Schedule B, Part I,
columns (o) and (p), are completed only
with respect to tested income CFCs (that
is, those CFCs with a positive amount in
Schedule B, Part I, column (e)).
Column (o), GILTI allocation ratio.
For each CFC listed in Schedule B, Part I,
column (a), that has an amount in
Schedule B, Part I, column (e), and the
U.S. shareholder listed in column (c),
divide the Part I, column (g), amount for
that U.S. shareholder by the Part II,
column (c), amount for that U.S.
shareholder. Enter the result to four
decimal places. See section 951A(f)(2).
Column (p), GILTI allocated to
tested income CFCs. For each CFC
listed in Schedule B, Part I, column (a),
that has an amount in Schedule B, Part I,
column (e), and the U.S. shareholder
listed in column (c), multiply the GILTI
allocation ratio for that CFC, listed in Part
I, column (o), by the amount of the U.S.
shareholder’s GILTI inclusion amount (that
is, the amount shown on that U.S.
shareholder’s Form 8992, Part II, line 5).
Enter the result in column (p) in whole
dollars only.
Line 1. Enter on line 1 the totals for Part I,
columns (e) through (p).
Note. The total amounts for Part I,
columns (e), (f), (k), and (m) should not
reflect items from a CFC more than once,
even if the CFC is listed more than once.

Instructions for Form 8992 (Rev. 12-2022)

Instructions for Part II
Column (a), Name of U.S. shareholder.
For each U.S. shareholder listed in Part I,
column (c), enter in Part II, column (a), the
name of each such shareholder, using a
single line for each such U.S. shareholder.
Column (b), EIN of U.S. shareholder.
Enter the EIN of each U.S. shareholder
listed in Part II, column (a).

Note. Each U.S. shareholder listed in Part
II, column (a), will enter their Part II,
column (f), amount on their Form 8992,
Part I, line 2.
Column (g), Consolidated QBAI. For
each U.S. shareholder listed in Part II,
column (a), enter the sum of all amounts
entered in Part I, column (i), with respect
to that U.S. shareholder. In other words, in
Part II, column (g), sort and then sum the
pro rata share of QBAI amounts listed in
Part I, column (i), by U.S. shareholder.
See Regulations section 1.1502-51(e)(4).

amount shown on Part II, line 2, column
(k), from the total amount shown on Part II,
line 2, column (j). If zero or less, enter -0-.
Column (m), Allocable share of consolidated specified interest expense.
For each U.S. shareholder listed in Part II,
column (a), multiply the GILTI allocation
ratio entered in Part II, column (d), with
respect to that U.S. shareholder by the
total amount shown on Part II, line 2,
column (l). See Regulations section
1.1502-51(e)(3)(ii).

DRAFT AS OF
October 31, 2022

Column (c), Aggregate tested income.
For each U.S. shareholder listed in Part II,
column (a), enter the sum of all amounts
entered in Part I, column (g), with respect
to that U.S. shareholder. In other words, in
Part II, column (c), sort and then sum the
pro rata share of tested income amounts
listed in Part I, column (g), by U.S.
shareholder. See Regulations section
1.1502-51(e)(1).

Note. Each U.S. shareholder listed in Part
II, column (a), will enter their Part II,
column (c), amount on their Form 8992,
Part I, line 1.
Column (d), GILTI allocation ratio. For
each U.S. shareholder listed in Part II,
column (a), divide the column (c) amount
for that U.S. shareholder by the total
amount shown on Part II, line 2, column
(c). See Regulations section 1.1502-51(e)
(10).
Note. The GILTI allocation ratio
computed here in Part II, column (d),
accords with the rules of Regulations
section 1.1502-51(e)(10), and differs from
the GILTI allocation ratio computed in Part
I, column (o), which accords with the rules
of section 951A(f)(2).
Column (e), Aggregate tested loss.
For each U.S. shareholder listed in Part II,
column (a), enter the sum of all amounts
entered in Part I, column (h), with respect
to that U.S. shareholder. In other words, in
Part II, column (e), sort and then sum the
pro rata share of tested loss amounts
listed in Part I, column (h), by U.S.
shareholder. See Regulations section
1.1502-51(e)(2).
Column (f), Allocable share of consolidated tested loss. For each U.S.
shareholder listed in Part II, column (a),
multiply the GILTI allocation ratio entered
in Part II, column (d), with respect to that
U.S. shareholder by the total amount
shown on Part II, line 2, column (e). See
Regulations section 1.1502-51(e)(3)(iii).

Instructions for Form 8992 (Rev. 12-2022)

Column (h), Allocable share of consolidated QBAI. For each U.S.
shareholder listed in Part II, column (a),
multiply the GILTI allocation ratio entered
in Part II, column (d), with respect to that
U.S. shareholder by the total amount
shown on Part II, line 2, column (g). See
Regulations section 1.1502-51(e)(3)(i).

Column (i), U.S. Deemed tangible income return (DTIR). For each U.S.
shareholder listed in Part II, column (a),
multiply the Part II, column (h), amount by
10% (0.10).
Note. Each U.S. shareholder listed in Part
II, column (a), will enter their Part II,
column (i), amount on their Form 8992,
Part II, line 2. See Regulations section
1.1502-51(e)(9).
Column (j), Consolidated tested interest expense. For each U.S. shareholder
listed in Part II, column (a), enter the sum
of all amounts entered in Part I, column (l),
with respect to that U.S. shareholder. In
other words, in Part II, column (j), sort and
then sum the pro rata share of tested
interest expense amounts listed in Part I,
column (l), by U.S. shareholder. See
Regulations section 1.1502-51(e)(5)(i).
Column (k), Consolidated tested interest income. For each U.S. shareholder
listed in Part II, column (a), enter the sum
of all amounts entered in Part I, column
(n), with respect to that U.S. shareholder.
In other words, in Part II, column (k), sort
and then sum the pro rata share of tested
interest income amounts listed in Part I,
column (n), by U.S. shareholder. See
Regulations section 1.1502-51(e)(5)(ii).
Column (l), Consolidated specified interest expense. For each U.S.
shareholder listed in Part II, column (a),
leave column (l) blank. However, on line 2
(Totals) for column (l), subtract the total

-5-

Note. Each U.S. shareholder listed in Part
II, column (a), will enter their Part II,
column (m), amount on their Form 8992,
Part II, line 3c.

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