Who must file — GILTI & Subpart F Planning?

U.S. shareholders of Controlled Foreign Corporations (CFCs) with net CFC tested income exceeding the 10% deemed tangible income return (QBAI).

Penalty — GILTI & Subpart F Planning?

Substantial understatement penalties (20% to 40%) plus interest on deferred liabilities.

Filed with annual Form 1040/1120 corporate or individual return.

Cross-Border Corporate

Global Intangible Low-Taxed Income (Form 8992)

Penalty: Substantial understatement penalties (20% to 40%) plus interest on deferred liabilities.
Deadline: Filed with annual Form 1040/1120 corporate or individual return.
Who must file: U.S. shareholders of Controlled Foreign Corporations (CFCs) with net CFC tested income exceeding the 10% deemed tangible income return (QBAI).
Statute of limitations: Indefinitely open if accompanying Form 5471 is missing.
Key parts & schedules: Form 8992 Schedule A · IRC §962 Election Statement · IRC §250 Deduction Statement

Failing to elect Section 962 for individual shareholders, leading to up to 37% tax without FTCs
Inaccurate calculation of Qualified Business Asset Investment (QBAI)

IRC §962 election execution to access corporate 10.5% effective tax rate and Section 960 indirect tax credits
Holding company restructuring to optimize high-tax exception rules under Treas. Reg. §1.951A-2

Next step

Describe your situation in three lines. We map the filings before any work starts.