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양식 8992 관련 기사

Form 8992, U.S. 주주는 Global Intangible Low-Taxed Income (GILTI)의 계산

12월 2023일

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  • 양식 8992 - 미국 주주는 Global Intangible Low-Taxed Income (GILTI)의 계산
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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  
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  
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  
may be submitted electronically to substituteforms@irs.gov,  
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.  
1167 is available at IRS.gov/Pub1167.  
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  
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.  
-2-  
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.  
-3-  
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).  
Columns (o) and (p). As explained in Steps necessary to  
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)