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                                                                                                        Department of the Treasury
                                                                                                        Internal Revenue Service
Instructions for Form 8992

(Rev. December 2022)
U.S. Shareholder Calculation of Global Intangible Low-Taxed Income (GILTI)

Section references are to the Internal Revenue   and Global Intangible Low-Taxed Income        U.S. shareholder. A U.S. shareholder of 
Code unless otherwise noted.                     (GILTI), and its instructions.                a foreign corporation is a U.S. person who 
                                                 Domestic partnerships. Domestic               owns (directly, indirectly, or constructively, 
Future Developments                              partnerships are no longer required to        within the meaning of section 958) 10% or 
For the latest information about                 complete Form 8992 or Schedule A (Form        more of the total combined voting power 
developments related to Form 8992 and            8992). Instead, domestic partnerships         of all the classes of voting stock of the 
its instructions, such as legislation            must complete Schedule K-2 (Form 1065),       foreign corporation or 10% or more of the 
enacted after they were published, go to         Part VI, and Schedule K-3 (Form 1065),        total value of shares of all classes of stock 
IRS.gov/Form8992.                                Part VI.                                      of the foreign corporation.
Additional guidance may be issued                                                              When and Where To File
subsequent to these instructions. Please         General Instructions                          In general, attach Form 8992 and 
review any additional information on                                                           Schedule A (Form 8992) to your income 
IRS.gov/Form8992 prior to completing             Purpose of Form                               tax return (or exempt organization return, 
Form 8992.                                       Public Law 115-97 (Tax Cuts and Jobs Act      as applicable) and file both by the due 
                                                 of 2017) enacted section 951A, which          date (including extensions) for that return.
What’s New                                       requires U.S. shareholders who own            Members of a U.S. consolidated group. 
                                                 (within the meaning of section 958(a)) a 
Form 8992.   Part II, line 5, of the form                                                      Attach Schedule B (Form 8992) and one 
                                                 CFC to include GILTI in gross income. 
shows the U.S. shareholder’s GILTI                                                             consolidated Form 8992 to the U.S. 
                                                 Form 8992 is used by a U.S. shareholder 
inclusion amount. Line 5 of the form                                                           consolidated group's income tax return 
                                                 to calculate the amount of the GILTI 
instructs filers to subtract line 4 from line 1.                                               and file both by the due date (including 
                                                 inclusion and to report related information. 
The following sentence has been added at                                                       extensions) for that return. See the 
                                                 Generally, Schedule A (Form 8992) is also 
the end of line 5 of the form: “If zero or                                                     instructions for Schedule B, later, for 
                                                 completed and attached to Form 8992. 
less, enter -0-.” This clarification is                                                        information regarding the steps necessary 
                                                 However, if the U.S. shareholder is a 
consistent with the “Note” that was already                                                    to complete Schedule B (Form 8992) and 
                                                 member of a U.S. consolidated group, 
present in the specific instructions for                                                       Form 8992.
                                                 Schedule B (Form 8992) is completed and 
Form 8992, Part II, line 5. It has now been                                                    S corporations that elect entity treat-
                                                 attached to Form 8992 instead.
added to the form to make the form more                                                        ment.    An S corporation that elects to be 
intuitive.                                       Who Must File                                 treated as an entity under Notice 2020-69 
Schedule A and Schedule B.       With            A U.S. shareholder (including a partner of    must complete Form 8992 and 
respect to Schedule A (Form 8992),               a domestic partnership) that owns, within     Schedule A (Form 8992) and attach them 
column (b), and Schedule B (Form 8992),          the meaning of section 958(a), stock in       to its Form 1120-S by the due date 
Part I, column (b), those columns request        one or more CFCs. See Regulations             (including extensions) for that return. For 
an employer identification number (EIN) or       sections 1.951A-1(e) and 1.6038-5(a).         additional information, see the Instructions 
                                                                                               for Form 1120-S.
reference ID number with respect to              Members of a U.S. consolidated group. 
Controlled Foreign Corporations (CFCs).          While each U.S. shareholder that is a         Computer-Generated Form 
With respect to each CFC, if the CFC has         member of a U.S. consolidated group is        8992
an EIN, the taxpayer must enter that EIN in      required to complete a separate Form          Generally, all computer-generated forms 
column (b). Taxpayers will no longer have        8992, these Forms 8992 should not be          must receive prior approval from the IRS 
the option to enter “APPLIED FOR” in             filed with the consolidated return. Instead,  and are subject to an annual review. 
column (b) in lieu of an EIN. If the CFC         a single consolidated Form 8992 must be       However, see the exception below. 
does not have an EIN, the taxpayer must          completed and filed with the consolidated     Requests for approval may be submitted 
enter a reference ID number that uniquely        group's return. See the instructions for      electronically to substituteforms@irs.gov, 
identifies the CFC. Taxpayers will no            Schedule B, later, for information            or requests may be mailed to: Internal 
longer have the option to enter                  regarding the steps necessary to complete     Revenue Service, Attention: Substitute 
“FOREIGNUS” in column (b) in lieu of a           Schedule B (Form 8992) and Form 8992.         Forms Program, SE:W:CAR:MP:P:TP, 
reference ID number. Also, if the taxpayer 
has filed or will be filing a Form 5471 with     S corporations that elect entity treat-       1111 Constitution Ave. NW, Room 6554, 
respect to the CFC, the reference ID             ment. An S corporation that elects to be      Washington, DC 20224.
number for that CFC must be the same on          treated as an entity under Notice 2020-69              Be sure to attach the approval 
Form 5471 and column (b) of either               must file Form 8992. For additional           !        letter to Form 8992. However, if 
Schedule A (Form 8992) or Schedule B             information, see the Instructions for Form    CAUTION  the computer-generated form is 
(Form 8992), Part I, as applicable.              1120-S.                                       identical to the IRS-prescribed form, it 
                                                 CFC. A CFC is generally a foreign             does not need to go through the approval 
Reminders                                        corporation of which more than 50% of the     process, and an attachment is not 
Form 8993 deduction. If you are eligible         total combined voting power or value is       necessary.
for a deduction under section 250 for your       owned directly, indirectly, or constructively 
GILTI inclusion, please see Form 8993,           (within the meaning of section 958) by        Every year, the IRS issues a revenue 
Section 250 Deduction for                        U.S. shareholders.                            procedure to provide guidance for filers of 
Foreign-Derived Intangible Income (FDII)                                                       computer-generated forms. In addition, 

Oct 27, 2022                                              Cat. No. 71351C

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every year, the IRS issues Pub. 1167,        parent as the person filing the return and      inclusion amount, if any, and to determine 
General Rules and Specifications for         enter its EIN in item A.                        the amount of the U.S. shareholder’s 
Substitute Forms and Schedules, which                                                        GILTI inclusion amount, if any, allocated to 
reprints the most recent applicable          Item B. Identifying Number                      each of its CFCs. If a U.S. shareholder 
revenue procedure. Pub. 1167 is available    If the name of the U.S. shareholder of the      does not file a Schedule I-1 (Form 5471) 
at IRS.gov/Pub1167.                          CFC(s) reported on this Form 8992 is            for a CFC that is part of its GILTI 
Corrections to Form 8992                     different from the name of the person filing    computation, for instance, due to an 
                                             this return, enter the U.S. shareholder’s       exception for multiple filers of the same 
If you file a Form 8992 that you later       identifying number. In the case of a U.S.       information, the U.S. shareholder will still 
determine is incomplete or incorrect, file a consolidated group, leave the name of the       need to provide amounts with respect to 
corrected Form 8992 with an amended tax      U.S. shareholder and item B blank.              each CFC as if the U.S. shareholder filed 
return, using the amended return                                                             Schedule I-1 (Form 5471) for that CFC.
instructions for the return with which you 
originally filed Form 8992. Write            Part I                                                  Due to space limitations, if you 
“Corrected” at the top of Form 8992 and      If the U.S. shareholder is not a member of      !       need to list more CFCs than fit on 
attach a statement identifying the           a U.S. consolidated group, to figure the        CAUTION one Schedule A (Form 8992), 
changes.                                     amounts to enter on lines 1 and 2, first        attach Schedule A—Continuation Sheet(s) 
                                             complete Schedule A (Form 8992),                to continue listing the CFCs and their 
Treaty-Based Return                          columns (a) through (f). See the specific       respective information. Do not write “See 
                                             instructions for Schedule A, later. Then,       attached” in the section and attach 
Positions                                    follow the applicable instructions on the       additional sheets.
You are generally required to file Form      face of Form 8992, Part I, lines 1 through 
8833, Treaty-Based Return Position           3, to determine the amounts to enter on         Column (a).   Enter the name of each 
Disclosure Under Section 6114 or             each of those lines.                            CFC. If the name of any of the CFCs being 
7701(b), to disclose a return position that                                                  reported on Schedule A (Form 8992) 
any treaty of the United States (such as an  If the amount on line 3 is greater than         changed within the past 3 years, include 
income tax treaty, an estate and gift tax    zero, complete Schedule A (Form 8992),          the prior name(s) in parentheses after the 
treaty, or a friendship, commerce, and       columns (g) through (l). If the amount on       current name.
navigation treaty):                          line 3 is zero or negative, do not complete 
                                                                                             Column (b).   With respect to each CFC 
•  Overrides or modifies any provision of    Part II of Form 8992 or Schedule A (Form 
                                                                                             reported on Schedule A, if the CFC has an 
the Internal Revenue Code; and               8992), columns (g) through (l). Include 
                                                                                             EIN, you must enter that EIN in column 
•  Causes, or potentially causes, a          Form 8992 and Schedule A (Form 8992) 
                                                                                             (b). Do not enter “APPLIED FOR” in 
reduction of any tax incurred at any time.   with your return.
                                                                                             column (b) in lieu of an EIN. If the CFC 
   See Form 8833 for exceptions.             If the U.S. shareholder is a member of          does not have an EIN, you must enter a 
                                             a U.S. consolidated group, see Steps            reference ID number that uniquely 
                                             necessary to complete Schedule B (Form          identifies the CFC. Do not enter 
Specific Instructions                        8992) and Form 8992, later.                     “FOREIGNUS” in column (b) in lieu of a 
                                                                                             reference ID number. For more 
Form 8992                                    Part II                                         information regarding reference ID 
                                                                                             numbers, see the instructions for Form 
Use Form 8992 to compute the U.S.            For each line on Form 8992, Part II, follow     5471, item 1b(2), Reference ID Number. 
shareholder’s GILTI inclusion amount.        the instructions on the face of the form to     Note that if a U.S. shareholder is required 
                                             determine the amount to enter on that line.     to file Schedule A (Form 8992) or 
   Complete Form 8992 as follows.                                                            Schedule B (Form 8992) with respect to a 
•  If the U.S. shareholder is not a member   Note.   If the amount on line 4 is greater 
of a U.S. consolidated group, use            than the amount on line 1, enter zero on        CFC, the reference ID number on Form 
Schedule A (Form 8992), to determine the     line 5.                                         5471 and the reference ID number used 
                                                                                             on Schedule A (Form 8992) or Schedule B 
amounts to enter on Form 8992, Part l.                                                       (Form 8992) for that CFC must be the 
•  If the U.S. shareholder is a member of a  For a corporate shareholder, enter the 
U.S. consolidated group, use Schedule B      Part II, line 5, result on the appropriate line same.
(Form 8992) to determine the amounts to      of Form 1120, Schedule C, or on the             Column (c).   Enter the U.S. dollar amount 
enter on Form 8992, Part l.                  comparable line of other corporate              of tested income, if any, from line 6 of 
                                             returns.                                        Schedule I-1 (Form 5471) for each CFC 
   Important: If completing Schedule B       For an individual shareholder, enter the        listed in column (a).
(Form 8992), see Steps necessary to          Part II, line 5, result on the appropriate      Column (d).   Enter the U.S. dollar amount 
complete Schedule B (Form 8992) and          “other income” line of Schedule 1 (Form         of tested loss, if any, from line 6 of 
Form 8992, later.                            1040), or on the comparable line of other       Schedule I-1 (Form 5471) for each CFC 
                                             noncorporate tax returns.                       listed in column (a).
Name Change
                                                                                             Column (e).   Enter your pro rata share (as 
If the name of the person filing the return  Schedule A                                      determined under Regulations section 
changed within the past 3 years, include     In the case of a U.S. shareholder that is       1.951A-1(d)(2)) of the tested income listed 
the prior name in parentheses after the      not a member of a U.S. consolidated             in column (c).
current name.                                group, the U.S. shareholder files 
                                             Schedule A (Form 8992), to report its pro       Column (f). Enter your pro rata share (as 
Item A. Identifying Number                   rata share of amounts for each CFC (the         determined under Regulations section 
The identifying number of an individual is   tax year of which ends with or within the       1.951A-1(d)(4)) of the tested loss listed in 
the individual’s social security number      shareholder’s tax year) from each CFC’s         column (d).
(SSN). The identifying number of all others  Schedule I-1 (Form 5471), Information for       Important: See the instructions for 
is their EIN. In the case of a U.S.          Global Intangible Low-Taxed Income, to          Form 8992, Part I, earlier, to determine if 
consolidated group, list the common          determine the U.S. shareholder’s GILTI 

                                                              -2-                            Instructions for Form 8992 (Rev. 12-2022)

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you are required to complete columns (g)     8992) the totals for columns (g) through (l)   b. Enter the totals for columns (e) 
through (l).                                 for Schedule A (Form 8992) and any             through (h) on line 1 of those columns. In 
                                             Schedule A—Continuation Sheets.                doing so, please note that the total 
Column (g).  Enter your pro rata share (as 
                                                                                            amounts for Part I, columns (e) and (f) 
determined under Regulations section 
1.951A-1(d)(3)) of the U.S. dollar amount    Schedule B                                     should not reflect items from any CFC 
                                                                                            more than once, even if the CFC is listed 
of QBAI from line 8 of Schedule I-1 (Form    Purpose of schedule.     Use Schedule B        more than once.
5471) for each tested income CFC.            to report amounts used in determining the 
                                             GILTI inclusion amount of each member of       c. If the line 1 total for Part I, column 
Note. If you have a tested loss for a        a consolidated group that is a U.S.            (h), equals or exceeds the line 1 total for 
particular CFC, no entry should be made      shareholder of any CFC. In doing so,           Part I, column (g), do not complete the 
for that CFC in this column. See             apply the rules of section 951A to each        remainder of Schedule B. Also, do not 
Regulations section 1.951A-3(b).             member in accordance with Regulations          complete the remainder of step 1 or any 
Column (h).  Enter your pro rata share (as   section 1.1502-51 as follows.                  portion of step 2. Proceed to step 3.
determined under Regulations section         Use Part I to report relevant amounts          d. If the line 1 total for Part I, column 
1.951A-1(d)(3)) of the tested loss QBAI      from Schedule I-1 (Form 5471) for each         (g), exceeds the line 1 total for Part I, 
amount of any tested loss CFC. The           CFC owned (within the meaning of section       column (h), complete Part I, columns (i) 
tested loss QBAI amount of a tested loss     958(a)) by any member of the U.S.              through (n), using the instructions 
CFC is the amount reported on                consolidated group as well as the pro rata     provided below. Enter the totals for 
Schedule I-1 (Form 5471), line 9c, that the  shares of such amounts for each member.        columns (i) through (n) on line 1 of those 
                                                                                            columns. In doing so, please note that the 
tested loss CFC would have had if it were    Use Part II to report the calculations         total amounts for Part I, columns (k) and 
instead a tested income CFC. See             necessary to determine the amounts that        (m), should not reflect items from any CFC 
Regulations sections 1.951A-4(b)(1)(i)       will be carried over to the Form 8992 of       more than once, even if the CFC is listed 
and 1.951A-4(b)(1)(iv), and example 5 of     each member that is a U.S. shareholder in      more than once.
Regulations section 1.951A-4(c)(5).          order to determine that member’s GILTI 
Column (i).  Enter your pro rata share (as   inclusion amount. See How to complete          e. Skip Part I, columns (o) and (p), for 
determined under Regulations section         and file Schedule B (Form 8992) and            now. Do not complete Part I, columns (o) 
1.951A-1(d)(6)) of the amount of tested      Form 8992 below.                               and (p), unless instructed to do so later.
interest income from Schedule I-1 (Form      Complete only one Schedule B (Form             f.    Complete all columns of 
5471), line 10c, for each CFC.               8992) for the U.S. consolidated group, and     Schedule B, Part II (columns (a) through 
Column (j).  Enter your pro rata share (as   provide a copy to each member of the           (m)), using the instructions provided 
determined under Regulations section         group.                                         below.
                                                                                            2. Complete a separate Form 8992 for 
1.951A-1(d)(5)) of tested interest expense   Computer-generated Schedule B.        A        each U.S. shareholder listed in 
from Schedule l-1 (Form 5471), line 9d.      computer-generated Schedule B can be           Schedule B (Form 8992), Part II, using the 
Column (k).  Before completing column        filed if it conforms to the IRS version of the instructions provided on the face of Form 
(k), enter the totals (including amounts     schedule. Expand Schedule B to properly        8992, to determine each U.S. 
from any Schedule A—Continuation             complete Parts I and II of the schedule if     shareholder’s GILTI inclusion amount.
Sheet(s)) of columns (c) through (j) on      the number of CFCs and/or U.S. 
line 1 for each column and complete Form     shareholders exceeds the number of lines       3. Complete a consolidated Form 
8992, Parts I and II. Then, for each CFC     on Part I or Part II.                          8992, as follows.
                                                                                            a. If the Schedule B (Form 8992), 
with an amount in column (e), divide that    How to complete and file Schedule B            line 1, total for Part I, column (h), equals or 
amount by the total on line 1, column (e).   (Form 8992) and Form 8992.    Complete         exceeds the line 1 total for Part I, column 
Enter the result here to four decimal        a single Schedule B (Form 8992) for all        (g): Enter the amount from Schedule B 
places. See section 951A(f)(2).              members of the U.S. consolidated group         (Form 8992), Part I, line 1, column (g), on 
Column (l).  For each CFC with an            that are U.S. shareholders of a CFC.           Form 8992, Part I, line 1. Enter the amount 
amount in column (e), multiply the column    Certain amounts from Schedule B (Form          from Schedule B, Part I, line 1, column (h), 
(k) ratio for that CFC by the Form 8992,     8992) are carried over to the consolidated     on Form 8992, Part I, line 2. Combine the 
Part II, line 5, amount and enter the result group’s Form(s) 8992. A separate Form          amounts shown on Form 8992, Part I, 
in column (l) in whole dollars only. This    8992 is completed for each member of the       lines 1 and 2, and enter the result on Form 
information is used in completing            consolidated group that is a U.S.              8992, Part I, line 3. Do not complete the 
Schedule J (Form 5471), Accumulated          shareholder of a CFC. Additionally, a          remainder of Form 8992. This is the 
Earnings and Profits (E&P) of CFC, and       consolidated Form 8992 is completed for        consolidated Form 8992 that will be filed 
Schedule P (Form 5471), Previously           the consolidated group as a whole. The         with the U.S. consolidated group’s income 
Taxed Earnings and Profits of U.S.           Schedule B (Form 8992) and the                 tax return. Do not complete the remainder 
Shareholder of Certain Foreign               consolidated Form 8992 are filed with the      of the steps listed below.
Corporations, for each CFC.                  consolidated group’s income tax return. 
                                             Schedule B (Form 8992) and Form 8992           b. If the Schedule B (Form 8992), 
Line 1                                       are completed using the following steps.       line 1, total for Part I, column (h), is less 
                                                                                            than the line 1 total for Part I, column (g): 
On line 1 of the first completed page of     Steps necessary to complete Sched-             For each line of the Form 8992, aggregate 
Schedule A (Form 8992), enter the totals     ule B (Form 8992) and Form 8992.               the amounts from the corresponding line 
for columns (c) through (f) for Schedule A 
(Form 8992) and any                          1. Complete one Schedule B (Form               of all Forms 8992 completed for each U.S. 
Schedule A—Continuation Sheets. If the       8992) for all members of the consolidated      shareholder from step 2, and enter the 
amount on your Form 8992, Part I, line 3,    group that are U.S. shareholders of a          total on the corresponding line of the 
is positive, you are required to complete    CFC, as follows.                               consolidated Form 8992. File the 
Schedule A, columns (g) through (l), and     a. Complete Part I, columns (a)                consolidated Form 8992 with the U.S. 
should also enter on line 1 of the first     through (h), using the instructions            consolidated group’s income tax return.
completed page of Schedule A (Form           provided below.

Instructions for Form 8992 (Rev. 12-2022)                          -3-

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4. Complete Schedule B (Form 8992),         Note. For each CFC listed in column (a),      the U.S. dollar amount of tested interest 
Part I, columns (o) and (p), using the      enter the column (e) amount on the            expense, if any, from Schedule I-1 (Form 
instructions provided below.                corresponding line of the U.S.                5471), line 9d.
                                            shareholder's applicable Form 1118, 
                                                                                          Column (l), Pro rata share of tested in-
Note. Do not file the Forms 8992 that       Schedule D, Part I, column 6, for that CFC 
                                                                                          terest expense. For each CFC listed in 
were completed for each U.S.                (that is, the Form 1118 that is being 
                                                                                          column (a) and the U.S. shareholder listed 
shareholder. Instead, keep them for your    completed for passive category income or 
                                                                                          in column (c), enter the U.S. shareholder's 
records so that they are available upon     general category income, as applicable).
request (for example, in the case of an                                                   pro rata share (as determined under 
examination).                               Column (f), Tested loss. For each CFC         Regulations section 1.951A-1(d)(5)) of the 
                                            listed in column (a), enter the U.S. dollar   CFC's tested interest expense listed in 
                                            amount of tested loss, if any, from line 6 of column (k).
Instructions for Part I                     Schedule I-1 (Form 5471).
                                                                                          Column (m), Tested interest income. 
Column (a), Name of CFC.     In column      Column (g), Pro rata share of tested in-      For each CFC listed in column (a), enter 
(a), list all CFCs, an interest in which is come. For each CFC listed in column (a)       the U.S. dollar amount of tested interest 
owned (within the meaning of section        and the U.S. shareholder listed in column     income, if any, from Schedule I-1 (Form 
958(a)) by any member of the                (c), enter the U.S. shareholder's pro rata    5471), line 10c.
consolidated group. If more than one        share (as determined under Regulations 
                                                                                          Column (n), Pro rata share of tested in-
member of the consolidated group owns       section 1.951A-1(d)(2)) of the CFC's 
                                                                                          terest income.  For each CFC listed in 
(within the meaning of section 958(a)) an   tested income listed in column (e).
interest in the same CFC, list the CFC on                                                 column (a) and the U.S. shareholder listed 
multiple lines, using a separate line for   Note. For each CFC listed in column (a),      in column (c), enter the U.S. shareholder's 
each member that owns an interest in the    enter the column (g) amount on the            pro rata share (as determined under 
CFC. Be sure to note the name and EIN of    corresponding line of the U.S.                Regulations section 1.951A-1(d)(6)) of the 
the member that is a U.S. shareholder of    shareholder's applicable Form 1118,           CFC's tested interest income listed in 
the CFC in columns (c) and (d). On each     Schedule D, Part I, column 5, for that CFC    column (m).
line, enter the name of the CFC in column   (that is, the Form 1118 that is being         Columns (o) and (p). As explained in 
(a). If the name of any of the CFCs being   completed for passive category income or      Steps necessary to complete Schedule B 
reported on Schedule B (Form 8992)          general category income, as applicable).      (Form 8992) and Form 8992, earlier, 
changed within the past 3 years, include                                                  Schedule B, Part I, columns (o) and (p), 
the prior name(s) in parentheses after the  Column (h), Pro rata share of tested 
current name.                               loss. For each CFC listed in column (a)       are completed only after Form 8992 has 
                                            and the U.S. shareholder listed in column     been completed. Also, Schedule B, Part I, 
Column (b), EIN or reference ID num-        (c), enter the U.S. shareholder's pro rata    columns (o) and (p), are completed only 
ber of CFC. With respect to each CFC        share (as determined under Regulations        with respect to tested income CFCs (that 
that must be reported on Schedule B, Part   section 1.951A-1(d)(4)) of the CFC's          is, those CFCs with a positive amount in 
I, if the CFC has an EIN, you must enter    tested loss listed in column (f).             Schedule B, Part I, column (e)).
that EIN in column (b). Do not enter                                                      Column (o), GILTI allocation ratio. 
“APPLIED FOR” in column (b) in lieu of an   Column (i), Pro rata share of QBAI.     For 
EIN. If the CFC does not have an EIN, you   each tested income CFC listed in column       For each CFC listed in Schedule B, Part I, 
must enter a reference ID number that       (a) and the U.S. shareholder listed in        column (a), that has an amount in 
uniquely identifies the CFC. Do not enter   column (c), enter the U.S. shareholder’s      Schedule B, Part I, column (e), and the 
“FOREIGNUS” in column (b) in lieu of a      pro rata share (as determined under           U.S. shareholder listed in column (c), 
reference ID number. For more               Regulations section 1.951A-1(d)(3)) of the    divide the Part I, column (g), amount for 
information regarding reference ID          tested income CFC’s QBAI from line 8 of       that U.S. shareholder by the Part II, 
numbers, see the instructions for Form      that CFC’s Schedule I-1 (Form 5471).          column (c), amount for that U.S. 
                                                                                          shareholder. Enter the result to four 
5471, item 1b(2), Reference ID Number.                                                    decimal places. See section 951A(f)(2).
Note that if a U.S. shareholder is required Note. If you have a tested loss for a 
to file Schedule A (Form 8992) or           particular CFC, no entry should be made       Column (p), GILTI allocated to 
Schedule B (Form 8992) with respect to a    for that CFC in Part I, column (i). See       tested income CFCs.  For each CFC 
CFC, the reference ID number on Form        Regulations section 1.951A-3(b).              listed in Schedule B, Part I, column (a), 
5471 and the reference ID number used       Column (j), Pro rata share of tested          that has an amount in Schedule B, Part I, 
on Schedule A (Form 8992) or Schedule B     loss QBAI amount. For each line where         column (e), and the U.S. shareholder 
(Form 8992) for that CFC must be the        there is a U.S. shareholder listed in         listed in column (c), multiply the GILTI 
same.                                       column (c) that owns an interest in a         allocation ratio for that CFC, listed in Part 
Column (c), Name of U.S. shareholder.       tested loss CFC listed in column (a) of that  I, column (o), by the amount of the U.S. 
For each CFC listed in column (a), enter in line, enter the U.S. shareholder’s pro rata   shareholder’s GILTI inclusion amount (that 
column (c) the name of each U.S.            share (as determined under Regulations        is, the amount shown on that U.S. 
shareholder that owns (within the meaning   section 1.951A-1(d)(3)) of the tested loss    shareholder’s Form 8992, Part II, line 5). 
of section 958(a)) an interest in that CFC. QBAI amount of the CFC. The tested loss       Enter the result in column (p) in whole 
                                            QBAI amount of a tested loss CFC is an        dollars only.
Column (d), EIN of U.S. shareholder.        amount equal to 10% of the QBAI from          Line 1. Enter on line 1 the totals for Part I, 
For each U.S. shareholder listed in column  Schedule I-1 (Form 5471), line 9c, that the   columns (e) through (p).
(c), enter the EIN of the U.S. shareholder. tested loss CFC would have had if it were 
Column (e), Tested income.   For each       instead a tested income CFC. See              Note. The total amounts for Part I, 
CFC listed in column (a), enter the U.S.    Regulations sections 1.951A-4(b)(1)(i)        columns (e), (f), (k), and (m) should not 
dollar amount of tested income, if any,     and 1.951A-4(b)(1)(iv), and example 5 of      reflect items from a CFC more than once, 
from line 6 of Schedule I-1 (Form 5471).    Regulations section 1.951A-4(c)(5).           even if the CFC is listed more than once.
                                            Column (k), Tested interest expense. 
                                            For each CFC listed in column (a), enter 

                                                  -4-                                     Instructions for Form 8992 (Rev. 12-2022)

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Instructions for Part II                      Note. Each U.S. shareholder listed in Part    amount shown on Part II, line 2, column 
                                              II, column (a), will enter their Part II,     (k), from the total amount shown on Part II, 
Column (a), Name of U.S. shareholder.         column (f), amount on their Form 8992,        line 2, column (j). If zero or less, enter -0-.
For each U.S. shareholder listed in Part I,   Part I, line 2.
column (c), enter in Part II, column (a), the                                               Column (m), Allocable share of con-
name of each such shareholder, using a        Column (g), Consolidated QBAI.            For solidated specified interest expense. 
single line for each such U.S. shareholder.   each U.S. shareholder listed in Part II,      For each U.S. shareholder listed in Part II, 
                                              column (a), enter the sum of all amounts      column (a), multiply the GILTI allocation 
Column (b), EIN of U.S. shareholder.          entered in Part I, column (i), with respect   ratio entered in Part II, column (d), with 
Enter the EIN of each U.S. shareholder        to that U.S. shareholder. In other words, in  respect to that U.S. shareholder by the 
listed in Part II, column (a).                Part II, column (g), sort and then sum the    total amount shown on Part II, line 2, 
Column (c), Aggregate tested income.          pro rata share of QBAI amounts listed in      column (l). See Regulations section 
For each U.S. shareholder listed in Part II,  Part I, column (i), by U.S. shareholder.      1.1502-51(e)(3)(ii).
column (a), enter the sum of all amounts      See Regulations section 1.1502-51(e)(4).
                                                                                            Note. Each U.S. shareholder listed in Part 
entered in Part I, column (g), with respect   Column (h), Allocable share of con-           II, column (a), will enter their Part II, 
to that U.S. shareholder. In other words, in  solidated QBAI.  For each U.S.                column (m), amount on their Form 8992, 
Part II, column (c), sort and then sum the    shareholder listed in Part II, column (a),    Part II, line 3c.
pro rata share of tested income amounts       multiply the GILTI allocation ratio entered 
listed in Part I, column (g), by U.S.         in Part II, column (d), with respect to that  Paperwork Reduction Act Notice.           We 
shareholder. See Regulations section          U.S. shareholder by the total amount          ask for the information on this form to carry 
1.1502-51(e)(1).                              shown on Part II, line 2, column (g). See     out the Internal Revenue laws of the 
                                              Regulations section 1.1502-51(e)(3)(i).
Note. Each U.S. shareholder listed in Part                                                  United States. You are required to give us 
II, column (a), will enter their Part II,     Column (i), U.S. Deemed tangible in-          the information. We need it to ensure that 
column (c), amount on their Form 8992,        come return (DTIR). For each U.S.             you are complying with these laws and to 
Part I, line 1.                               shareholder listed in Part II, column (a),    allow us to figure and collect the right 
                                              multiply the Part II, column (h), amount by   amount of tax.
Column (d), GILTI allocation ratio.       For 10% (0.10).                                   You are not required to provide the 
each U.S. shareholder listed in Part II, 
column (a), divide the column (c) amount      Note. Each U.S. shareholder listed in Part    information requested on a form that is 
for that U.S. shareholder by the total        II, column (a), will enter their Part II,     subject to the Paperwork Reduction Act 
amount shown on Part II, line 2, column       column (i), amount on their Form 8992,        unless the form displays a valid OMB 
(c). See Regulations section 1.1502-51(e)     Part II, line 2. See Regulations section      control number. Books or records relating 
(10).                                         1.1502-51(e)(9).                              to a form or its instructions must be 
                                                                                            retained as long as their contents may 
Note. The GILTI allocation ratio              Column (j), Consolidated tested inter-        become material in the administration of 
computed here in Part II, column (d),         est expense.   For each U.S. shareholder      any Internal Revenue law. Generally, tax 
accords with the rules of Regulations         listed in Part II, column (a), enter the sum  returns and return information are 
section 1.1502-51(e)(10), and differs from    of all amounts entered in Part I, column (l), confidential, as required by section 6103.
the GILTI allocation ratio computed in Part   with respect to that U.S. shareholder. In 
I, column (o), which accords with the rules   other words, in Part II, column (j), sort and The time needed to complete and file 
of section 951A(f)(2).                        then sum the pro rata share of tested         this form will vary depending on individual 
                                              interest expense amounts listed in Part I,    circumstances. The estimated burden for 
Column (e), Aggregate tested loss.            column (l), by U.S. shareholder. See          individual and business taxpayers filing 
For each U.S. shareholder listed in Part II,  Regulations section 1.1502-51(e)(5)(i).       this form is approved under OMB control 
column (a), enter the sum of all amounts                                                    number 1545-0123 and is included in the 
entered in Part I, column (h), with respect   Column (k), Consolidated tested inter-        estimates shown in the instructions for 
to that U.S. shareholder. In other words, in  est income.    For each U.S. shareholder      their individual and business income tax 
Part II, column (e), sort and then sum the    listed in Part II, column (a), enter the sum  returns.
pro rata share of tested loss amounts         of all amounts entered in Part I, column 
listed in Part I, column (h), by U.S.         (n), with respect to that U.S. shareholder.   If you have comments concerning the 
shareholder. See Regulations section          In other words, in Part II, column (k), sort  accuracy of these time estimates or 
1.1502-51(e)(2).                              and then sum the pro rata share of tested     suggestions for making this form simpler, 
                                              interest income amounts listed in Part I,     we would be happy to hear from you. See 
Column (f), Allocable share of consoli-       column (n), by U.S. shareholder. See          the instructions for the tax return with 
dated tested loss. For each U.S.              Regulations section 1.1502-51(e)(5)(ii).      which this form is filed.
shareholder listed in Part II, column (a), 
multiply the GILTI allocation ratio entered   Column (l), Consolidated specified in-
in Part II, column (d), with respect to that  terest expense.  For each U.S. 
U.S. shareholder by the total amount          shareholder listed in Part II, column (a), 
shown on Part II, line 2, column (e). See     leave column (l) blank. However, on line 2 
Regulations section 1.1502-51(e)(3)(iii).     (Totals) for column (l), subtract the total 

Instructions for Form 8992 (Rev. 12-2022)                      -5-