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GILTI and FDII Calculations

August 30, 2022

Review the fundamentals of the global intangible low-tax income (GILTI) and the foreign-derived intangible income (FDII) tax regimes. GILTI and FDII were both created by the Tax Cuts and Jobs Act of 2017 (TCJA). Pub. L. No. 115-97. The TCJA enacted I.R.C. Section 951A, which requires U.S. shareholders who own (within the meaning of I.R.C. 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. 

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