GILTI JEOPARDY

IRC

100

The code section that the GILTI income inclusion amount falls under in the IRC

951A

200

The code section that the GILTI deduction falls under in the IRC

Section 250

300

This code section requires a gross-up of 100%

Section 78

400

The amount of deduction for tax years 2018-2025

50% of GILTI income

500

The amount of deduction for tax years after 2025

37.5% GILTI income

Equation

100

X - (10% of the quarterly avg adjusted basis of depreciable assets - interest expense)

Net CFC tested income

200

In the second part of the equation, what is "10% of the quarterly avg adjusted basis of depreciable assets - interest expense" considered?

Net Deemed Tangible Income

300

Net CFC tested income is CFC income less allocable deductions but excludes ______ income

Subpart F

400

Under GILTI, there is a limitation of _____ on the foreign tax credit for foreign taxes deemed paid

80%

500

This is the GILTI deduction for a corporation with $1,000,000 Sec. 951A GILTI inclusion

$500,000

Applications

100

In comparison to FDII, this nickname is given to GILTI

The stick

200

GILTI is determined at this level

Shareholder level

300

GILTI income is reported in its own _____ basket

Foreign tax credit limitation

400

This is the amount of time allowed for carry back and carry forward of excess credits (FTCL)

None

500

A US shareholder includes it ______ share of a CFC's GILTI

pro rata