The IRS recently released an early draft of Form 8992, U.S. Shareholder Calculation of Global Intangible Low-Taxed Income, along with instructions providing e-file guidance for taxpayers with multiple Form 8992 filing requirements relating to tax year 2019.
Generally, a U.S. shareholder owning stock in one or more Controlled Foreign Corporations (CFC) that generate tested income must file a Form 8992. In the case of consolidated groups, a taxpayer may need to file more than one Form 8992. The IRS has provided two alternatives for consolidated group taxpayers e-filing multiple Form 8992s.
If a taxpayer chooses to file a single consolidated Form 8992, instructions for reporting consolidated group amounts are within the Form 8992. Notably, when computing Form 8992, Schedule A, if a CFC is owned by two or more members of the consolidated group, each ownership interest should be reported on separate lines. If this approach is taken, the IRS requires two additional attachments associating U.S. shareholders to their respecting CFCs and a white paper showing the shareholder’s GILTI attributes and their applicable share of the GILTI inclusion.
If a taxpayer chooses to file multiple Forms 8992, the IRS instructs taxpayers to include the Forms 8992 as PDF attachments. Each Form 8992 attachment should display the corresponding U.S. shareholder’s name within the file name.
Contacts:
Yasmin Dirks
Manager
Washington, D.C.
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