Muoto 8992 Ohjeita
U.S. Osakkeenomistajien laskenta Global Intangible Low-Taxed Income (GILTI)
Joulukuu 2023
Liittyvät lomakkeet
- Muoto 8992 - Yhdysvaltain osakkeenomistajien laskenta Global Intangible Low-Taxed Income (GILTI)
Department of the Treasury
Internal Revenue Service
Instructions for Form 8992
(Rev. December 2023)
(Use with the December 2022 revisions of Form 8992, Schedule A (Form 8992), and
Schedule B (Form 8992))
U.S. Shareholder Calculation of Global Intangible Low-Taxed Income (GILTI)
Section references are to the Internal Revenue Code unless
otherwise noted.
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 U.S. consolidated group’s income tax
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 elected entity treatment. An S
corporation that elected to be treated as owning stock of a
CFC under Proposed Regulations section 1.958-1(e)(2) and
is a U.S. shareholder of a CFC must file Form 8992. For
additional information, see the Instructions for Form 1120-S.
CFC. A CFC is generally a foreign corporation if more than
50% of the total combined voting power of all classes of stock
of the foreign corporation or more than 50% of the total value
of the stock of the foreign corporation is owned (directly,
indirectly, or constructively within the meaning of section 958)
by U.S. shareholders on any day during its taxable year.
U.S. shareholder. A U.S. shareholder of a foreign
corporation is a U.S. person (as defined in section 957(c))
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.
Future Developments
For the latest information about developments related to
Form 8992 and its instructions, such as legislation enacted
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
On page 1 of these instructions, we have added a “Penalties”
section to alert filers to penalties that may apply under
sections 6038(b) and (c).
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) and Global Intangible Low-Taxed Income
(GILTI), and its instructions.
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.
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 elected entity treatment. An S
corporation that elected to be treated as owning stock of a
CFC under Proposed Regulations section 1.958-1(e)(2) and
is a U.S. shareholder of a CFC 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.
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)) stock in 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 person who was a U.S. shareholder (including a partner of
a domestic partnership) of at least one foreign corporation at
any time during the foreign corporation’s tax year ending with
or within the U.S. shareholder’s tax year, and who owned,
within the meaning of section 958(a), stock in that foreign
corporation on the last day in the foreign corporation’s tax
year in which it was a CFC. See Regulations sections
1.958-1(d) and 1.6038-5(a).
Penalties
Penalties under sections 6038(b) and (c) may apply for failure
to report the information required on this form.
Sep 26, 2023
Cat. No. 71351C
Computer-Generated Form 8992
Item A. Identifying Number
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
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.
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 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.
Be sure to attach the approval letter to Form 8992.
However, if the computer-generated form is identical
!
CAUTION
to the IRS-prescribed form, it does not need to go
through the approval process, and an attachment is not
necessary.
Part I
If the U.S. shareholder is not a member of a U.S.
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.
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.
Corrections to Form 8992
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.
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.
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.
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):
Part II
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.
Overrides or modifies any provision of the Internal
•
Revenue Code; and
For a corporate shareholder, enter the Part II, line 5, result
on line 17 of Form 1120, Schedule C, or on the comparable
line of other corporate returns.
Causes, or potentially causes, a reduction of any tax
•
incurred at any time.
For an individual shareholder, enter the Part II, line 5,
result on line 8o of Schedule 1 (Form 1040), or on the
comparable line of other noncorporate tax returns.
See Form 8833 for exceptions from reporting.
Specific Instructions
Schedule A
Form 8992
In the case of a U.S. shareholder that is not a member of a
U.S. consolidated group, the U.S. shareholder files
Use Form 8992 to compute the U.S. shareholder’s GILTI
inclusion amount.
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 U.S. 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
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.
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
Form 8992, later.
Name Change
If the name of the person filing the return changed within the
past 3 years, include the prior name(s) in parentheses after
the current name.
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Instructions for Form 8992 (Rev. 12-2023)
Due to space limitations, if you need to list more
CFCs than fit on one Schedule A (Form 8992), attach
Schedule A—Continuation Sheet(s) to continue
Column (j), Pro rata share of tested interest expense.
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), GILTI allocation ratio. Before completing
column (k), on line 1 of the first page of Schedule A (Form
8992), enter the totals for columns (c) through (j) for
Schedule A (Form 8992) and any Schedule A—Continuation
Sheets using the instructions provided below, 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 to four decimal places. See
section 951A(f)(2).
!
CAUTION
listing the CFCs and their respective information. Do not
write “See attached” on Schedule A (Form 8992) and attach
additional sheets.
Column (a), Name of CFC. 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), EIN or reference ID number of CFC. With
respect to each CFC reported on Schedule A (Form 8992), 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), Tested income. 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), Tested loss. 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 (l), GILTI allocated to tested income CFCs.
Before completing column (l), complete Form 8992, Part II.
Then, 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 Controlled Foreign Corporation, 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 (Form
8992), columns (g) through (l), and should also enter on
line 1 of the first completed page of Schedule A (Form 8992)
the totals for columns (g) through (l) for Schedule A (Form
8992) and any Schedule A—Continuation Sheets.
Column (e), Pro rata share of tested income. Enter your
pro rata share (as determined under Regulations section
1.951A-1(d)(2)) of the tested income listed in column (c).
Schedule B
Column (f), Pro rata share of tested loss. 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 you are required to complete columns
(g) through (l).
Purpose of schedule. Use Schedule B (Form 8992) to
report amounts used in determining the GILTI inclusion
amount of each member of a U.S. 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.
Column (g), Pro rata share of QBAI. 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
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.
Schedule I-1 (Form 5471) for each tested income CFC.
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), Pro rata share of tested loss QBAI amount.
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, which is 10% of the amount that would
be the QBAI of that tested loss CFC 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), Pro rata share of tested interest income.
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.
Complete only one Schedule B (Form 8992) for the U.S.
consolidated group, and provide a copy to each member of
the U.S. consolidated group.
Computer-generated Schedule B. A computer-generated
Schedule B (Form 8992) can be filed if it conforms to the IRS
version of the schedule. Expand Schedule B (Form 8992) 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.
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Instructions for Form 8992 (Rev. 12-2023)
For each line of the consolidated 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.
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 U.S. consolidated group’s
Form(s) 8992. A separate Form 8992 is completed for each
member of the U.S. consolidated group that is a U.S.
shareholder of a CFC. Additionally, a consolidated Form
8992 is completed for the U.S. consolidated group as a
whole. The Schedule B (Form 8992) and the consolidated
Form 8992 are filed with the U.S. consolidated group’s
income tax return. Schedule B (Form 8992) and Form 8992
are completed using the following steps.
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).
Steps necessary to complete Schedule B (Form 8992)
Part I of Schedule B
and Form 8992.
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 U.S. consolidated group. If
more than one member of the U.S. 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
(Form 8992), 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.
1. Complete one Schedule B (Form 8992) for all
members of the U.S. 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.
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 (Form 8992). 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 (Form 8992), 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.
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).
3. Complete a consolidated Form 8992, as follows.
a. If 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 (Form 8992), 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.
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).
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).
b. If Schedule B (Form 8992), line 1, total for Part I,
column (h), is less than the line 1 total for Part I, column (g):
-4-
Instructions for Form 8992 (Rev. 12-2023)
Column (o), GILTI allocation ratio. For each CFC listed
in Schedule B (Form 8992), Part I, column (a), that has an
amount in Schedule B (Form 8992), 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 (Form 8992), Part I,
column (a), that has an amount in Schedule B (Form 8992),
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.
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).
Line 1. Enter on line 1 the totals for Part I, columns (e)
through (n) and column (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.
Part II of Schedule B
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 U.S. shareholder, using a
single line for each such U.S. shareholder.
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 the amount
reported on Schedule I-1 (Form 5471), line 9c, which is 10%
of the amount that would be the QBAI of that tested loss CFC
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 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).
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).
Schedule B (Form 8992), Part I, columns (o) and (p), are
completed only after Form 8992 has been completed. Also,
Schedule B (Form 8992), 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 (Form
8992), Part I, column (e)).
Column (b), EIN of U.S. shareholder. Enter the EIN of
each U.S. shareholder listed in Part II, column (a).
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 such 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 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
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Instructions for Form 8992 (Rev. 12-2023)
shown on Part II, line 2, column (e). See Regulations section
1.1502-51(e)(3)(iii).
column (l) blank. However, on Part II, line 2 (Totals) for
column (l), subtract the total 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).
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).
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 (m), amount on their Form 8992,
Part II, line 3c.
Paperwork Reduction Act Notice. We ask for the
information on this form to carry out the Internal Revenue
laws of the United States. You are required to give us the
information. We need it to ensure that you are complying with
these laws and to allow us to figure and collect the right
amount of tax.
You are not required to provide the information requested
on a form that is subject to the Paperwork Reduction Act
unless the form displays a valid OMB control number. Books
or records relating to a form or its instructions must be
retained as long as their contents may become material in the
administration of any Internal Revenue law. Generally, tax
returns and return information are confidential, as required by
section 6103.
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.
The time needed to complete and file this form will vary
depending on individual circumstances. The estimated
burden for individual and business taxpayers filing this form is
approved under OMB control number 1545-0123 and is
included in the estimates shown in the instructions for their
individual and business income tax returns.
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.
If you have comments concerning the accuracy of these
time estimates or suggestions for making this form simpler,
we would be happy to hear from you. See the instructions for
the tax return with which this form is filed.
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
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Instructions for Form 8992 (Rev. 12-2023)