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                                                                                           Department of the Treasury
                                                                                           Internal Revenue Service
Instructions for Form 8992

(Rev. December 2023)

(Use with the December 2022 revisions of Form 8992, Schedule A (Form 8992), and 
Schedule B (Form 8992))
U.S. Shareholder Calculation of Global Intangible Low-Taxed Income (GILTI)

Section references are to the Internal Revenue Code unless     Members of a U.S. consolidated group.       While each U.S. 
otherwise noted.                                               shareholder that is a member of a U.S. consolidated group is 
                                                               required to complete a separate Form 8992, these Forms 
Future Developments                                            8992 should not be filed with the consolidated return. 
                                                               Instead, a single consolidated Form 8992 must be completed 
For the latest information about developments related to       and filed with the U.S. consolidated group’s income tax 
Form 8992 and its instructions, such as legislation enacted    return. See the instructions for Schedule B, later, for 
after they were published, go to IRS.gov/Form8992.             information regarding the steps necessary to complete 
Additional guidance may be issued subsequent to these          Schedule B (Form 8992) and Form 8992.
instructions. Please review any additional information on      S corporations that elected entity treatment.   An S 
IRS.gov/Form8992 prior to completing Form 8992.                corporation that elected to be treated as owning stock of a 
                                                               CFC under Proposed Regulations section 1.958-1(e)(2) and 
What’s New                                                     is a U.S. shareholder of a CFC must file Form 8992. For 
On page 1 of these instructions, we have added a “Penalties”   additional information, see the Instructions for Form 1120-S.
section to alert filers to penalties that may apply under      CFC.      A CFC is generally a foreign corporation if more than 
sections 6038(b) and (c).                                      50% of the total combined voting power of all classes of stock 
                                                               of the foreign corporation or more than 50% of the total value 
Reminders                                                      of the stock of the foreign corporation is owned (directly, 
                                                               indirectly, or constructively within the meaning of section 958) 
Form 8993 deduction. If you are eligible for a deduction       by U.S. shareholders on any day during its taxable year.
under section 250 for your GILTI inclusion, please see Form 
                                                               U.S. shareholder. A U.S. shareholder of a foreign 
8993, Section 250 Deduction for Foreign-Derived Intangible 
                                                               corporation is a U.S. person (as defined in section 957(c)) 
Income (FDII) and Global Intangible Low-Taxed Income 
                                                               who owns (directly, indirectly, or constructively, within the 
(GILTI), and its instructions.
                                                               meaning of section 958) 10% or more of the total combined 
Domestic partnerships.    Domestic partnerships are no         voting power of all the classes of voting stock of the foreign 
longer required to complete Form 8992 or Schedule A (Form      corporation or 10% or more of the total value of shares of all 
8992). Instead, domestic partnerships must complete            classes of stock of the foreign corporation.
Schedule K-2 (Form 1065), Part VI, and Schedule K-3 (Form 
1065), Part VI.                                                When and Where To File
                                                               In general, attach Form 8992 and Schedule A (Form 8992) to 
                                                               your income tax return (or exempt organization return, as 
General Instructions                                           applicable) and file both by the due date (including 
                                                               extensions) for that return.
Purpose of Form
Public Law 115-97 (Tax Cuts and Jobs Act of 2017) enacted      Members of a U.S. consolidated group.       Attach 
section 951A, which requires U.S. shareholders who own         Schedule B (Form 8992) and one consolidated Form 8992 to 
(within the meaning of section 958(a)) stock in a CFC to       the U.S. consolidated group’s income tax return and file both 
include GILTI in gross income. Form 8992 is used by a U.S.     by the due date (including extensions) for that return. See the 
shareholder to calculate the amount of the GILTI inclusion     instructions for Schedule B, later, for information regarding 
and to report related information. Generally, Schedule A       the steps necessary to complete Schedule B (Form 8992) 
(Form 8992) is also completed and attached to Form 8992.       and Form 8992.
However, if the U.S. shareholder is a member of a U.S.         S corporations that elected entity treatment.   An S 
consolidated group, Schedule B (Form 8992) is completed        corporation that elected to be treated as owning stock of a 
and attached to Form 8992 instead.                             CFC under Proposed Regulations section 1.958-1(e)(2) and 
                                                               is a U.S. shareholder of a CFC must complete Form 8992 
Who Must File                                                  and Schedule A (Form 8992) and attach them to its Form 
A person who was a U.S. shareholder (including a partner of    1120-S by the due date (including extensions) for that return. 
a domestic partnership) of at least one foreign corporation at For additional information, see the Instructions for Form 
any time during the foreign corporation’s tax year ending with 1120-S.
or within the U.S. shareholder’s tax year, and who owned, 
within the meaning of section 958(a), stock in that foreign    Penalties
corporation on the last day in the foreign corporation’s tax   Penalties under sections 6038(b) and (c) may apply for failure 
year in which it was a CFC. See Regulations sections           to report the information required on this form.
1.958-1(d) and 1.6038-5(a).

Sep 26, 2023                                              Cat. No. 71351C

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Computer-Generated Form 8992                                         Item A. Identifying Number
Generally, all computer-generated forms must receive prior           The identifying number of an individual is the individual’s 
approval from the IRS and are subject to an annual review.           social security number (SSN). The identifying number of all 
However, see the exception below. Requests for approval              others is their EIN. In the case of a U.S. consolidated group, 
may be submitted electronically to substituteforms@irs.gov,          list the common parent as the person filing the return and 
or requests may be mailed to: Internal Revenue Service,              enter its EIN in item A.
Attention: Substitute Forms Program, SE:W:CAR:MP:P:TP, 
1111 Constitution Ave. NW, Room 6554, Washington, DC                 Item B. Identifying Number
20224.                                                               If the name of the U.S. shareholder of the CFC(s) reported on 
        Be sure to attach the approval letter to Form 8992.          this Form 8992 is different from the name of the person filing 
                                                                     this return, enter the U.S. shareholder’s identifying number. In 
CAUTION to the IRS-prescribed form, it does not need to go 
  !     However, if the computer-generated form is identical         the case of a U.S. consolidated group, leave the name of the 
through the approval process, and an attachment is not               U.S. shareholder and item B blank.
necessary.
                                                                     Part I
Every year, the IRS issues a revenue procedure to provide            If the U.S. shareholder is not a member of a U.S. 
guidance for filers of computer-generated forms. In addition,        consolidated group, to figure the amounts to enter on lines 1 
every year, the IRS issues Pub. 1167, General Rules and              and 2, first complete Schedule A (Form 8992), columns (a) 
Specifications for Substitute Forms and Schedules, which             through (f). See the specific instructions for Schedule A, later. 
reprints the most recent applicable revenue procedure. Pub.          Then, follow the applicable instructions on the face of Form 
1167 is available at IRS.gov/Pub1167.                                8992, Part I, lines 1 through 3, to determine the amounts to 
                                                                     enter on each of those lines.
Corrections to Form 8992                                             If the amount on line 3 is greater than zero, complete 
If you file a Form 8992 that you later determine is incomplete       Schedule A (Form 8992), columns (g) through (l). If the 
or incorrect, file a corrected Form 8992 with an amended tax         amount on line 3 is zero or negative, do not complete Part II 
return, using the amended return instructions for the return         of Form 8992 or Schedule A (Form 8992), columns (g) 
with which you originally filed Form 8992. Write “Corrected”         through (l). Include Form 8992 and Schedule A (Form 8992) 
at the top of Form 8992 and attach a statement identifying the       with your return.
changes.
                                                                     If the U.S. shareholder is a member of a U.S. consolidated 
Treaty-Based Return Positions                                        group, see Steps necessary to complete Schedule B (Form 
You are generally required to file Form 8833, Treaty-Based           8992) and Form 8992, later.

Return Position Disclosure Under Section 6114 or 7701(b), to         Part II
disclose a return position that any treaty of the United States 
(such as an income tax treaty, an estate and gift tax treaty, or     For each line on Form 8992, Part II, follow the instructions on 
a friendship, commerce, and navigation treaty):                      the face of the form to determine the amount to enter on that 
• Overrides or modifies any provision of the Internal                line.
Revenue Code; and                                                    For a corporate shareholder, enter the Part II, line 5, result 
• Causes, or potentially causes, a reduction of any tax              on line 17 of Form 1120, Schedule C, or on the comparable 
incurred at any time.                                                line of other corporate returns.
  See Form 8833 for exceptions from reporting.                       For an individual shareholder, enter the Part II, line 5, 
                                                                     result on line 8o of Schedule 1 (Form 1040), or on the 
                                                                     comparable line of other noncorporate tax returns.
Specific Instructions
                                                                     Schedule A
Form 8992                                                            In the case of a U.S. shareholder that is not a member of a 
Use Form 8992 to compute the U.S. shareholder’s GILTI                U.S. consolidated group, the U.S. shareholder files 
inclusion amount.                                                    Schedule A (Form 8992), to report its pro rata share of 
                                                                     amounts for each CFC (the tax year of which ends with or 
  Complete Form 8992 as follows.                                     within the U.S. shareholder’s tax year) from each CFC’s 
• If the U.S. shareholder is not a member of a U.S.                  Schedule I-1 (Form 5471), Information for Global Intangible 
consolidated group, use Schedule A (Form 8992) to                    Low-Taxed Income, to determine the U.S. shareholder’s GILTI 
determine the amounts to enter on Form 8992, Part l.                 inclusion amount, if any, and to determine the amount of the 
• If the U.S. shareholder is a member of a U.S. consolidated         U.S. shareholder’s GILTI inclusion amount, if any, allocated to 
group, use Schedule B (Form 8992) to determine the                   each of its CFCs. If a U.S. shareholder does not file a 
amounts to enter on Form 8992, Part l.                               Schedule I-1 (Form 5471) for a CFC that is part of its GILTI 
                                                                     computation, for instance, due to an exception for multiple 
  Important: If completing Schedule B (Form 8992), see               filers of the same information, the U.S. shareholder will still 
Steps necessary to complete Schedule B (Form 8992) and               need to provide amounts with respect to each CFC as if the 
Form 8992, later.                                                    U.S. shareholder filed Schedule I-1 (Form 5471) for that CFC.
Name Change
If the name of the person filing the return changed within the 
past 3 years, include the prior name(s) in parentheses after 
the current name.

                                                                 -2-                  Instructions for Form 8992 (Rev. 12-2023)

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        Due to space limitations, if you need to list more          Column (j), Pro rata share of tested interest expense. 
!       CFCs than fit on one Schedule A (Form 8992), attach         Enter your pro rata share (as determined under Regulations 
CAUTION Schedule A—Continuation Sheet(s) to continue 
                                                                    section 1.951A-1(d)(5)) of tested interest expense from 
listing the CFCs and their respective information. Do not           Schedule l-1 (Form 5471), line 9d.
write “See attached” on Schedule A (Form 8992) and attach 
additional sheets.                                                  Column (k), GILTI allocation ratio. Before completing 
                                                                    column (k), on line 1 of the first page of Schedule A (Form 
Column (a), Name of CFC. Enter the name of each CFC. If             8992), enter the totals for columns (c) through (j) for 
the name of any of the CFCs being reported on Schedule A            Schedule A (Form 8992) and any Schedule A—Continuation 
(Form 8992) changed within the past 3 years, include the            Sheets using the instructions provided below, and complete 
prior name(s) in parentheses after the current name.                Form 8992, Parts I and II. Then, for each CFC with an amount 
                                                                    in column (e), divide that amount by the total on line 1, 
Column (b), EIN or reference ID number of CFC.        With          column (e). Enter the result to four decimal places. See 
respect to each CFC reported on Schedule A (Form 8992), if          section 951A(f)(2).
the CFC has an EIN, you must enter that EIN in column (b). 
Do not enter “APPLIED FOR” in column (b) in lieu of an EIN.         Column (l), GILTI allocated to tested income CFCs. 
If the CFC does not have an EIN, you must enter a reference         Before completing column (l), complete Form 8992, Part II. 
ID number that uniquely identifies the CFC. Do not enter            Then, for each CFC with an amount in column (e), multiply 
“FOREIGNUS” in column (b) in lieu of a reference ID number.         the column (k) ratio for that CFC by the Form 8992, Part II, 
For more information regarding reference ID numbers, see            line 5, amount and enter the result in column (l) in whole 
the instructions for Form 5471, item 1b(2), Reference ID            dollars only. This information is used in completing 
Number. Note that if a U.S. shareholder is required to file         Schedule J (Form 5471), Accumulated Earnings and Profits 
Schedule A (Form 8992) or Schedule B (Form 8992) with               (E&P) of Controlled Foreign Corporation, and Schedule P 
respect to a CFC, the reference ID number on Form 5471 and          (Form 5471), Previously Taxed Earnings and Profits of U.S. 
the reference ID number used on Schedule A (Form 8992) or           Shareholder of Certain Foreign Corporations, for each CFC.
Schedule B (Form 8992) for that CFC must be the same.
                                                                    Line 1
Column (c), Tested income.     Enter the U.S. dollar amount 
                                                                    On line 1 of the first completed page of Schedule A (Form 
of tested income, if any, from line 6 of Schedule I-1 (Form 
                                                                    8992), enter the totals for columns (c) through (f) for 
5471) for each CFC listed in column (a).
                                                                    Schedule A (Form 8992) and any Schedule A—Continuation 
Column (d), Tested loss. Enter the U.S. dollar amount of            Sheets. If the amount on your Form 8992, Part I, line 3, is 
tested loss, if any, from line 6 of Schedule I-1 (Form 5471) for    positive, you are required to complete Schedule A (Form 
each CFC listed in column (a).                                      8992), columns (g) through (l), and should also enter on 
Column (e), Pro rata share of tested income.       Enter your       line 1 of the first completed page of Schedule A (Form 8992) 
pro rata share (as determined under Regulations section             the totals for columns (g) through (l) for Schedule A (Form 
1.951A-1(d)(2)) of the tested income listed in column (c).          8992) and any Schedule A—Continuation Sheets.

Column (f), Pro rata share of tested loss. Enter your pro           Schedule B
rata share (as determined under Regulations section 
1.951A-1(d)(4)) of the tested loss listed in column (d).            Purpose of schedule.       Use Schedule B (Form 8992) to 
                                                                    report amounts used in determining the GILTI inclusion 
Important: See the instructions for Form 8992, Part I,              amount of each member of a U.S. consolidated group that is 
earlier, to determine if you are required to complete columns       a U.S. shareholder of any CFC. In doing so, apply the rules of 
(g) through (l).                                                    section 951A to each member in accordance with 
Column (g), Pro rata share of QBAI. Enter your pro rata             Regulations section 1.1502-51 as follows.
share (as determined under Regulations section 1.951A-1(d)          Use Part I to report relevant amounts from Schedule I-1 
(3)) of the U.S. dollar amount of QBAI from line 8 of               (Form 5471) for each CFC owned (within the meaning of 
Schedule I-1 (Form 5471) for each tested income CFC.                section 958(a)) by any member of the U.S. consolidated 
                                                                    group as well as the pro rata shares of such amounts for each 
Note. If you have a tested loss for a particular CFC, no entry      member.
should be made for that CFC in this column. See Regulations 
                                                                    Use Part II to report the calculations necessary to 
section 1.951A-3(b).
                                                                    determine the amounts that will be carried over to the Form 
Column (h), Pro rata share of tested loss QBAI amount.              8992 of each member that is a U.S. shareholder in order to 
Enter your pro rata share (as determined under Regulations          determine that member’s GILTI inclusion amount. See How to 
section 1.951A-1(d)(3)) of the tested loss QBAI amount of           complete and file Schedule B (Form 8992) and Form 8992 
any tested loss CFC. The tested loss QBAI amount of a               below.
tested loss CFC is the amount reported on Schedule I-1              Complete only one Schedule B (Form 8992) for the U.S. 
(Form 5471), line 9c, which is 10% of the amount that would         consolidated group, and provide a copy to each member of 
be the QBAI of that tested loss CFC if it were instead a tested     the U.S. consolidated group.
income CFC. See Regulations sections 1.951A-4(b)(1)(i) and 
1.951A-4(b)(1)(iv), and example 5 of Regulations section            Computer-generated Schedule B.      A computer-generated 
1.951A-4(c)(5).                                                     Schedule B (Form 8992) can be filed if it conforms to the IRS 
                                                                    version of the schedule. Expand Schedule B (Form 8992) to 
Column (i), Pro rata share of tested interest income.               properly complete Parts I and II of the schedule if the number 
Enter your pro rata share (as determined under Regulations          of CFCs and/or U.S. shareholders exceeds the number of 
section 1.951A-1(d)(6)) of the amount of tested interest            lines on Part I or Part II.
income from Schedule I-1 (Form 5471), line 10c, for each 
CFC.

Instructions for Form 8992 (Rev. 12-2023)                        -3-

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How to complete and file Schedule B (Form 8992) and                   For each line of the consolidated Form 8992, aggregate the 
Form 8992. Complete a single Schedule B (Form 8992) for               amounts from the corresponding line of all Forms 8992 
all members of the U.S. consolidated group that are U.S.              completed for each U.S. shareholder from step 2, and enter 
shareholders of a CFC. Certain amounts from Schedule B                the total on the corresponding line of the consolidated Form 
(Form 8992) are carried over to the U.S. consolidated group’s         8992. File the consolidated Form 8992 with the U.S. 
Form(s) 8992. A separate Form 8992 is completed for each              consolidated group’s income tax return.
member of the U.S. consolidated group that is a U.S.                  4. Complete Schedule B (Form 8992), Part I, columns (o) 
shareholder of a CFC. Additionally, a consolidated Form               and (p), using the instructions provided below.
8992 is completed for the U.S. consolidated group as a 
whole. The Schedule B (Form 8992) and the consolidated                Note. Do not file the Forms 8992 that were completed for 
Form 8992 are filed with the U.S. consolidated group’s                each U.S. shareholder. Instead, keep them for your records 
income tax return. Schedule B (Form 8992) and Form 8992               so that they are available upon request (for example, in the 
are completed using the following steps.                              case of an examination).

Steps necessary to complete Schedule B (Form 8992)                    Part I of Schedule B
and Form 8992. 
                                                                      Column (a), Name of CFC.    In column (a), list all CFCs, an 
1. Complete one Schedule B (Form 8992) for all 
                                                                      interest in which is owned (within the meaning of section 
members of the U.S. consolidated group that are U.S. 
                                                                      958(a)) by any member of the U.S. consolidated group. If 
shareholders of a CFC, as follows.
                                                                      more than one member of the U.S. consolidated group owns 
a. Complete Part I, columns (a) through (h), using the                (within the meaning of section 958(a)) an interest in the same 
instructions provided below.                                          CFC, list the CFC on multiple lines, using a separate line for 
b. Enter the totals for columns (e) through (h) on line 1 of          each member that owns an interest in the CFC. Be sure to 
those columns. In doing so, please note that the total                note the name and EIN of the member that is a U.S. 
amounts for Part I, columns (e) and (f) should not reflect            shareholder of the CFC in columns (c) and (d). On each line, 
items from any CFC more than once, even if the CFC is listed          enter the name of the CFC in column (a). If the name of any 
more than once.                                                       of the CFCs being reported on Schedule B (Form 8992) 
c. If the line 1 total for Part I, column (h), equals or              changed within the past 3 years, include the prior name(s) in 
exceeds the line 1 total for Part I, column (g), do not complete      parentheses after the current name.
the remainder of Schedule B (Form 8992). Also, do not                 Column (b), EIN or reference ID number of CFC.       With 
complete the remainder of step 1 or any portion of step 2.            respect to each CFC that must be reported on Schedule B 
Proceed to step 3.                                                    (Form 8992), Part I, if the CFC has an EIN, you must enter 
d. If the line 1 total for Part I, column (g), exceeds the            that EIN in column (b). Do not enter “APPLIED FOR” in 
line 1 total for Part I, column (h), complete Part I, columns (i)     column (b) in lieu of an EIN. If the CFC does not have an EIN, 
through (n), using the instructions provided below. Enter the         you must enter a reference ID number that uniquely identifies 
totals for columns (i) through (n) on line 1 of those columns.        the CFC. Do not enter “FOREIGNUS” in column (b) in lieu of 
In doing so, please note that the total amounts for Part I,           a reference ID number. For more information regarding 
columns (k) and (m), should not reflect items from any CFC            reference ID numbers, see the instructions for Form 5471, 
more than once, even if the CFC is listed more than once.             item 1b(2), Reference ID Number. Note that if a U.S. 
e. Skip Part I, columns (o) and (p), for now. Do not                  shareholder is required to file Schedule A (Form 8992) or 
complete Part I, columns (o) and (p), unless instructed to do         Schedule B (Form 8992) with respect to a CFC, the reference 
so later.                                                             ID number on Form 5471 and the reference ID number used 
                                                                      on Schedule A (Form 8992) or Schedule B (Form 8992) for 
f. Complete all columns of Schedule B (Form 8992), Part               that CFC must be the same.
II (columns (a) through (m)), using the instructions provided 
below.                                                                Column (c), Name of U.S. shareholder.  For each CFC 
                                                                      listed in column (a), enter in column (c) the name of each 
2. Complete a separate Form 8992 for each U.S. 
                                                                      U.S. shareholder that owns (within the meaning of section 
shareholder listed in Schedule B (Form 8992), Part II, using 
                                                                      958(a)) an interest in that CFC.
the instructions provided on the face of Form 8992, to 
determine each U.S. shareholder’s GILTI inclusion amount.             Column (d), EIN of U.S. shareholder.   For each U.S. 
3. Complete a consolidated Form 8992, as follows.                     shareholder listed in column (c), enter the EIN of the U.S. 
                                                                      shareholder.
a. If Schedule B (Form 8992), line 1, total for Part I, 
column (h), equals or exceeds the line 1 total for Part I,            Column (e), Tested income.      For each CFC listed in column 
column (g): Enter the amount from Schedule B (Form 8992),             (a), enter the U.S. dollar amount of tested income, if any, from 
Part I, line 1, column (g), on Form 8992, Part I, line 1. Enter       line 6 of Schedule I-1 (Form 5471).
the amount from Schedule B (Form 8992), Part I, line 1, 
column (h), on Form 8992, Part I, line 2. Combine the                 Note. For each CFC listed in column (a), enter the column 
amounts shown on Form 8992, Part I, lines 1 and 2, and                (e) amount on the corresponding line of the U.S. 
enter the result on Form 8992, Part I, line 3. Do not complete        shareholder’s applicable Form 1118, Schedule D, Part I, 
the remainder of Form 8992. This is the consolidated Form             column 6, for that CFC (that is, the Form 1118 that is being 
8992 that will be filed with the U.S. consolidated group’s            completed for passive category income or general category 
income tax return. Do not complete the remainder of the               income, as applicable).
steps listed below.                                                   Column (f), Tested loss. For each CFC listed in column (a), 
b. If Schedule B (Form 8992), line 1, total for Part I,               enter the U.S. dollar amount of tested loss, if any, from line 6 
column (h), is less than the line 1 total for Part I, column (g):     of Schedule I-1 (Form 5471).

                                                                  -4-             Instructions for Form 8992 (Rev. 12-2023)

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Column (g), Pro rata share of tested income.     For each          Column (o), GILTI allocation ratio. For each CFC listed 
CFC listed in column (a) and the U.S. shareholder listed in        in Schedule B (Form 8992), Part I, column (a), that has an 
column (c), enter the U.S. shareholder’s pro rata share (as        amount in Schedule B (Form 8992), Part I, column (e), and 
determined under Regulations section 1.951A-1(d)(2)) of the        the U.S. shareholder listed in column (c), divide the Part I, 
CFC’s tested income listed in column (e).                          column (g), amount for that U.S. shareholder by the Part II, 
                                                                   column (c), amount for that U.S. shareholder. Enter the result 
Note. For each CFC listed in column (a), enter the column          to four decimal places. See section 951A(f)(2).
(g) amount on the corresponding line of the U.S.                   Column (p), GILTI allocated to tested income CFCs. 
shareholder’s applicable Form 1118, Schedule D, Part I,            For each CFC listed in Schedule B (Form 8992), Part I, 
column 5, for that CFC (that is, the Form 1118 that is being       column (a), that has an amount in Schedule B (Form 8992), 
completed for passive category income or general category          Part I, column (e), and the U.S. shareholder listed in column 
income, as applicable).                                            (c), multiply the GILTI allocation ratio for that CFC, listed in 
Column (h), Pro rata share of tested loss. For each CFC            Part I, column (o), by the amount of the U.S. shareholder’s 
listed in column (a) and the U.S. shareholder listed in column     GILTI inclusion amount (that is, the amount shown on that 
(c), enter the U.S. shareholder’s pro rata share (as               U.S. shareholder’s Form 8992, Part II, line 5). Enter the result 
determined under Regulations section 1.951A-1(d)(4)) of the        in column (p) in whole dollars only.
CFC’s tested loss listed in column (f).                            Line 1. Enter on line 1 the totals for Part I, columns (e) 
Column (i), Pro rata share of QBAI.     For each tested            through (n) and column (p).
income CFC listed in column (a) and the U.S. shareholder 
                                                                   Note. The total amounts for Part I, columns (e), (f), (k), and 
listed in column (c), enter the U.S. shareholder’s pro rata 
                                                                   (m) should not reflect items from a CFC more than once, 
share (as determined under Regulations section 1.951A-1(d)
                                                                   even if the CFC is listed more than once.
(3)) of the tested income CFC’s QBAI from line 8 of that 
CFC’s Schedule I-1 (Form 5471).                                    Part II of Schedule B
Note. If you have a tested loss for a particular CFC, no entry     Column (a), Name of U.S. shareholder.      For each U.S. 
should be made for that CFC in Part I, column (i). See             shareholder listed in Part I, column (c), enter in Part II, 
Regulations section 1.951A-3(b).                                   column (a), the name of each such U.S. shareholder, using a 
Column (j), Pro rata share of tested loss QBAI amount.             single line for each such U.S. shareholder.
For each line where there is a U.S. shareholder listed in          Column (b), EIN of U.S. shareholder.     Enter the EIN of 
column (c) that owns an interest in a tested loss CFC listed in    each U.S. shareholder listed in Part II, column (a).
column (a) of that line, enter the U.S. shareholder’s pro rata 
share (as determined under Regulations section 1.951A-1(d)         Column (c), Aggregate tested income.       For each U.S. 
(3)) of the tested loss QBAI amount of the CFC. The tested         shareholder listed in Part II, column (a), enter the sum of all 
loss QBAI amount of a tested loss CFC is the amount                amounts entered in Part I, column (g), with respect to that 
reported on Schedule I-1 (Form 5471), line 9c, which is 10%        U.S. shareholder. In other words, in Part II, column (c), sort 
of the amount that would be the QBAI of that tested loss CFC       and then sum the pro rata share of tested income amounts 
if it were instead a tested income CFC. See Regulations            listed in Part I, column (g), by such U.S. shareholder. See 
sections 1.951A-4(b)(1)(i) and 1.951A-4(b)(1)(iv), and             Regulations section 1.1502-51(e)(1).
example 5 of Regulations section 1.951A-4(c)(5).                   Note. Each U.S. shareholder listed in Part II, column (a), will 
Column (k), Tested interest expense.    For each CFC listed        enter their Part II, column (c), amount on their Form 8992, 
in column (a), enter the U.S. dollar amount of tested interest     Part I, line 1.
expense, if any, from Schedule I-1 (Form 5471), line 9d.           Column (d), GILTI allocation ratio. For each U.S. 
Column (l), Pro rata share of tested interest expense.             shareholder listed in Part II, column (a), divide the column (c) 
For each CFC listed in column (a) and the U.S. shareholder         amount for that U.S. shareholder by the total amount shown 
listed in column (c), enter the U.S. shareholder’s pro rata        on Part II, line 2, column (c). See Regulations section 
share (as determined under Regulations section 1.951A-1(d)         1.1502-51(e)(10).
(5)) of the CFC’s tested interest expense listed in column (k).
                                                                   Note. The GILTI allocation ratio computed in Part II, column 
Column (m), Tested interest income.     For each CFC listed        (d), accords with the rules of Regulations section 
in column (a), enter the U.S. dollar amount of tested interest     1.1502-51(e)(10), and differs from the GILTI allocation ratio 
income, if any, from Schedule I-1 (Form 5471), line 10c.           computed in Part I, column (o), which accords with the rules 
Column (n), Pro rata share of tested interest income.              of section 951A(f)(2).
For each CFC listed in column (a) and the U.S. shareholder         Column (e), Aggregate tested loss.  For each U.S. 
listed in column (c), enter the U.S. shareholder’s pro rata        shareholder listed in Part II, column (a), enter the sum of all 
share (as determined under Regulations section 1.951A-1(d)         amounts entered in Part I, column (h), with respect to that 
(6)) of the CFC’s tested interest income listed in column (m).     U.S. shareholder. In other words, in Part II, column (e), sort 
Columns (o) and (p). As explained in Steps necessary to            and then sum the pro rata share of tested loss amounts listed 
complete Schedule B (Form 8992) and Form 8992, earlier,            in Part I, column (h), by U.S. shareholder. See Regulations 
Schedule B (Form 8992), Part I, columns (o) and (p), are           section 1.1502-51(e)(2).
completed only after Form 8992 has been completed. Also,           Column (f), Allocable share of consolidated tested loss. 
Schedule B (Form 8992), Part I, columns (o) and (p), are           For each U.S. shareholder listed in Part II, column (a), 
completed only with respect to tested income CFCs (that is,        multiply the GILTI allocation ratio entered in Part II, column 
those CFCs with a positive amount in Schedule B (Form              (d), with respect to that U.S. shareholder by the total amount 
8992), Part I, column (e)).

Instructions for Form 8992 (Rev. 12-2023)                       -5-

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The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

shown on Part II, line 2, column (e). See Regulations section         column (l) blank. However, on Part II, line 2 (Totals) for 
1.1502-51(e)(3)(iii).                                                 column (l), subtract the total amount shown on Part II, line 2, 
                                                                      column (k), from the total amount shown on Part II, line 2, 
Note. Each U.S. shareholder listed in Part II, column (a), will       column (j). If zero or less, enter -0-.
enter their Part II, column (f), amount on their Form 8992, Part 
I, line 2.                                                            Column (m), Allocable share of consolidated specified 
                                                                      interest expense. For each U.S. shareholder listed in Part 
Column (g), Consolidated QBAI. For each U.S.                          II, column (a), multiply the GILTI allocation ratio entered in 
shareholder listed in Part II, column (a), enter the sum of all       Part II, column (d), with respect to that U.S. shareholder by 
amounts entered in Part I, column (i), with respect to that U.S.      the total amount shown on Part II, line 2, column (l). See 
shareholder. In other words, in Part II, column (g), sort and         Regulations section 1.1502-51(e)(3)(ii).
then sum the pro rata share of QBAI amounts listed in Part I, 
column (i), by U.S. shareholder. See Regulations section              Note. Each U.S. shareholder listed in Part II, column (a), will 
1.1502-51(e)(4).                                                      enter their Part II, column (m), amount on their Form 8992, 
                                                                      Part II, line 3c.
Column (h), Allocable share of consolidated QBAI.        For 
each U.S. shareholder listed in Part II, column (a), multiply 
                                                                      Paperwork Reduction Act Notice.        We ask for the 
the GILTI allocation ratio entered in Part II, column (d), with 
                                                                      information on this form to carry out the Internal Revenue 
respect to that U.S. shareholder by the total amount shown 
                                                                      laws of the United States. You are required to give us the 
on Part II, line 2, column (g). See Regulations section 
                                                                      information. We need it to ensure that you are complying with 
1.1502-51(e)(3)(i).
                                                                      these laws and to allow us to figure and collect the right 
Column (i), U.S. Deemed tangible income return (DTIR).                amount of tax.
For each U.S. shareholder listed in Part II, column (a), 
multiply the Part II, column (h), amount by 10% (0.10).               You are not required to provide the information requested 
                                                                      on a form that is subject to the Paperwork Reduction Act 
Note. Each U.S. shareholder listed in Part II, column (a), will       unless the form displays a valid OMB control number. Books 
enter their Part II, column (i), amount on their Form 8992, Part      or records relating to a form or its instructions must be 
II, line 2. See Regulations section 1.1502-51(e)(9).                  retained as long as their contents may become material in the 
                                                                      administration of any Internal Revenue law. Generally, tax 
Column (j), Consolidated tested interest expense.        For          returns and return information are confidential, as required by 
each U.S. shareholder listed in Part II, column (a), enter the        section 6103.
sum of all amounts entered in Part I, column (l), with respect 
to that U.S. shareholder. In other words, in Part II, column (j),     The time needed to complete and file this form will vary 
sort and then sum the pro rata share of tested interest               depending on individual circumstances. The estimated 
expense amounts listed in Part I, column (l), by U.S.                 burden for individual and business taxpayers filing this form is 
shareholder. See Regulations section 1.1502-51(e)(5)(i).              approved under OMB control number 1545-0123 and is 
                                                                      included in the estimates shown in the instructions for their 
Column (k), Consolidated tested interest income.         For          individual and business income tax returns.
each U.S. shareholder listed in Part II, column (a), enter the 
sum of all amounts entered in Part I, column (n), with respect        If you have comments concerning the accuracy of these 
to that U.S. shareholder. In other words, in Part II, column (k),     time estimates or suggestions for making this form simpler, 
sort and then sum the pro rata share of tested interest               we would be happy to hear from you. See the instructions for 
income amounts listed in Part I, column (n), by U.S.                  the tax return with which this form is filed.
shareholder. See Regulations section 1.1502-51(e)(5)(ii).
Column (l), Consolidated specified interest expense. 
For each U.S. shareholder listed in Part II, column (a), leave 

                                                                  -6-                  Instructions for Form 8992 (Rev. 12-2023)