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What specific categories of income are considered Subpart F income?
My CFC earns a mix of income — some from selling products, some from licensing IP, some from investing excess cash, and some from providing consulting services to related companies. I need to figure out which of these fall into Subpart F. Can you break down each category of Subpart F income with examples? I especially want to understand foreign personal holding company income since that seems to be the broadest bucket.
Related Questions
What is GILTI and how does it affect U.S. shareholders of foreign corporations?
I keep hearing about GILTI in the context of international tax reform. I'm a U.S. person who owns a foreign company, and someone told me I might owe tax on income my foreign company earns even if I never take a dividend. That sounds crazy to me. Can someone explain what GILTI actually is, how it works at a high level, and who it applies to? I want to understand the basics before I talk to my CPA.
I'm a foreign person owning a U.S. LLC — do I need to worry about GILTI?
I'm a non-U.S. resident who owns a single-member LLC in the United States. My LLC provides consulting services to clients in the U.S. and abroad. A friend told me about GILTI and said I should check if it applies to me. But everything I read says GILTI is for U.S. shareholders of foreign corporations. I'm a foreign person owning a U.S. entity — isn't that the opposite? Do I need to worry about GILTI at all, or is this a non-issue for someone in my situation?
How do you calculate GILTI? What are tested income, QBAI, and net DTIR?
I understand GILTI at a high level but I'm struggling with the actual calculation. My CPA mentioned terms like 'tested income,' 'QBAI,' and 'net deemed tangible income return' and I got lost. I own a U.S. holding company that has two CFCs — one is profitable and the other is running at a loss. Can someone walk me through the mechanics of how GILTI is actually computed? And does the loss from one CFC offset the income from the other?
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