TAX 9869 Lecture Notes - Lecture 54: Carried Interest, Foreign Tax Credit
Document Summary
1. aggregate pro rata share of tested income of all cfcs minus aggregate pro rata share of. Tested loss of all cfcs equals u. s. shareholder"s net cfc tested income. Shareholder"s net cfc tested income minus net deemed tangible return equals gilti. 3. gilti amount plus section 78 gross-up equals u. s. Shareholder inclusion minus 50% deduction times 21% rate equals tentative gilti tax. 5. tentative gilti tax minus deemed paid credits equals u. s. tax liability. No partner owns 10% directly or indirectly. Since no partner owns the cfc 10% or more directly, indirectly, gilti is not the issue. No 10% partners that are ussh, gilti is not a problem. Proposed rules say can do the same thing for subpart f income. If cfc generates sub f, can apply the same thing to the situation here with sub f, you have a 10% owner. If you have a 10% owner, then you say i look through-has to pick up sub.
