GILTI - Global Intangible Low-Taxed Income  

IRC Section 951A requires U.S. shareholders of a CFC to currently include in gross income their global intangible low taxed income, or GILTI, earned through one or more CFCs regardless of whether the shareholder's CFCs have any items that must be included in gross income under IRC Section 951(a). A U.S. person that is a U.S. shareholder with respect to one or more CFCs computes a single GILTI inclusion for the tax year. That amount is determined by first computing the U.S. shareholder's pro rata share of specified CFC-level items in the same way a U.S. shareholder determines its pro rata share of subpart F income. Net tested income is determined at the shareholder level by aggregating the shareholder's pro rata shares of tested income or tested loss of each CFC with respect to which the shareholder is a U.S. shareholder. The GILTI provisions presume a normal return on a CFC's fixed assets of 10%, which is exempt from tax. The base on which a CFC earns its exempt 10% return is its qualified business asset investment (QBAI). A U.S. shareholder's exempt return in calculating its GILTI inclusion is 10% of its aggregate pro rata shares of the QBAI of each CFC with respect to which it is a U.S. Shareholder for a tax year, reduced by interest expense for which the corresponding interest income has not been taken into account under the GILTI provisions. This advanced level course focuses on the development and expansion of in-depth knowledge, skill and application of global intangible low taxed income. This course is most appropriate for the professional with some experience on this topic or the professional seeking to expand his or her knowledge base and who may be a seasoned professional within an organization. This course also may be appropriate for other professionals with specialized knowledge in this topic.