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                                                                                                      Department of the Treasury
                                                                                                      Internal Revenue Service
Instructions for Form 8992

(Rev. December 2021)
U.S. Shareholder Calculation of Global Intangible Low-Taxed Income (GILTI)

Section references are to the Internal Revenue Schedule B (Form 8992) is completed and        S corporations that elect entity treat-
Code unless otherwise noted.                   attached to Form 8992 instead.                 ment.   An S corporation that elects to be 
Future Developments                            Who Must File                                  treated as an entity under Notice 2020-69 
                                                                                              must complete Form 8992 and 
                                               A U.S. shareholder (including a partner of     Schedule A (Form 8992) and attach them 
For the latest information about               a domestic partnership) that owns, within      to its Form 1120-S by the due date 
developments related to Form 8992 and          the meaning of section 958(a), stock in        (including extensions) for that return. For 
its instructions, such as legislation          one or more CFCs. See Regulations              additional information, see the Instructions 
enacted after they were published, go to       sections 1.951A-1(e) and 1.6038-5(a).          for Form 1120-S.
IRS.gov/Form8992.                              Members of a U.S. consolidated group. 
Additional guidance may be issued              While each U.S. shareholder that is a          Computer-Generated Form 
subsequent to these instructions. Please       member of a U.S. consolidated group is         8992
review any additional information on           required to complete a separate Form           Generally, all computer-generated forms 
IRS.gov/Form8992 prior to completing           8992, these Forms 8992 should not be           must receive prior approval from the IRS 
Form 8992.                                     filed with the consolidated return. Instead,   and are subject to an annual review. 
                                               a single consolidated Form 8992 must be        However, see the exception below. 
                                               completed and filed with the consolidated      Requests for approval may be submitted 
What’s New                                     group's return. See the instructions for       electronically to substituteforms@irs.gov, 
New separate Schedule A.       Schedule A      Schedule B, later, for information             or requests may be mailed to: Internal 
is now a separate schedule. It is no longer    regarding the steps necessary to complete      Revenue Service, Attention: Substitute 
part of the base Form 8992. Taxpayers          Schedule B (Form 8992) and Form 8992.          Forms Program, SE:W:CAR:MP:P:TP, 
are now required to attach either separate     S corporations that elect entity treat-        1111 Constitution Ave. NW, Room 6554, 
Schedule A or separate Schedule B,             ment. An S corporation that elects to be       Washington, DC 20224.
depending upon whether the U.S.                treated as an entity under Notice 2020-69              Be sure to attach the approval 
shareholder of the Controlled Foreign          must file Form 8992. For additional               !    letter to Form 8992. However, if 
Corporation (CFC) is a member of a U.S.        information, see the Instructions for Form     CAUTION the computer-generated form is 
consolidated group.                            1120-S.                                        identical to the IRS-prescribed form, it 
Domestic partnerships.       Domestic          CFC. A CFC is generally a foreign              does not need to go through the approval 
partnerships are no longer required to         corporation of which more than 50% of the      process, and an attachment is not 
complete Form 8992 or Schedule A (Form         total combined voting power or value is        necessary.
8992). Instead, domestic partnerships          owned directly, indirectly, or constructively 
must complete Schedule K-2 (Form 1065),        (within the meaning of section 958) by         Every year, the IRS issues a revenue 
Part VI, and Schedule K-3 (Form 1065),         U.S. shareholders.                             procedure to provide guidance for filers of 
Part VI.                                                                                      computer-generated forms. In addition, 
                                               U.S. shareholder.  A U.S. shareholder of       every year, the IRS issues Pub. 1167, 
                                               a foreign corporation is a U.S. person who     General Rules and Specifications for 
Reminders                                      owns (directly, indirectly, or constructively, Substitute Forms and Schedules, which 
Form 8993 deduction. If you are eligible       within the meaning of section 958) 10% or      reprints the most recent applicable 
for a deduction under section 250 for your     more of the total combined voting power        revenue procedure. Pub. 1167 is available 
GILTI inclusion, please see Form 8993,         of all the classes of voting stock of the      at IRS.gov/Pub1167.
Section 250 Deduction for                      foreign corporation or 10% or more of the 
Foreign-Derived Intangible Income (FDII)       total value of shares of all classes of stock  Corrections to Form 8992
and Global Intangible Low-Taxed Income         of the foreign corporation.                    If you file a Form 8992 that you later 
(GILTI), and its instructions.                                                                determine is incomplete or incorrect, file a 
                                               When and Where To File                         corrected Form 8992 with an amended tax 
                                               In general, attach Form 8992 and               return, using the amended return 
General Instructions                           Schedule A (Form 8992) to your income          instructions for the return with which you 
                                               tax return (or exempt organization return,     originally filed Form 8992. Write 
Purpose of Form                                as applicable) and file both by the due        “Corrected” at the top of Form 8992 and 
Public Law 115-97 (Tax Cuts and Jobs Act       date (including extensions) for that return.   attach a statement identifying the 
of 2017) enacted section 951A, which           Members of a U.S. consolidated group.          changes.
requires U.S. shareholders who own             Attach Schedule B (Form 8992) and one 
(within the meaning of section 958(a)) a       consolidated Form 8992 to the U.S.             Treaty-Based Return 
CFC to include GILTI in gross income.          consolidated group's income tax return         Positions
Form 8992 is used by a U.S. shareholder        and file both by the due date (including       You are generally required to file Form 
to calculate the amount of the GILTI           extensions) for that return. See the           8833, Treaty-Based Return Position 
inclusion and to report related information.   instructions for Schedule B, later, for        Disclosure Under Section 6114 or 
Generally, Schedule A (Form 8992) is also      information regarding the steps necessary      7701(b), to disclose a return position that 
completed, and attached to Form 8992.          to complete Schedule B (Form 8992) and         any treaty of the United States (such as an 
However, if the U.S. shareholder is a          Form 8992.                                     income tax treaty, an estate and gift tax 
member of a U.S. consolidated group, 

Nov 08, 2021                                              Cat. No. 71351C

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treaty, or a friendship, commerce, and        columns (g) through (l). If the amount on    Column (b).   Please refer to the 
navigation treaty):                           line 3 is zero or negative, do not complete  instructions for Form 5471, item 1b(2), 
• Overrides or modifies any provision of      Part II of Form 8992 or Schedule A (Form     Reference ID Number. Note that if a U.S. 
the Internal Revenue Code; and                8992), columns (g) through (l). Include      shareholder is required to file Schedule A 
• Causes, or potentially causes, a            Form 8992 and Schedule A (Form 8992)         (Form 8992) or Schedule B (Form 8992) 
reduction of any tax incurred at any time.    with your return.                            with respect to a CFC, the reference ID 
                                                                                           number on Form 5471 and the reference 
  See Form 8833 for exceptions.               If the U.S. shareholder is a member of       ID number used on Schedule A (Form 
                                              a U.S. consolidated group, see Steps         8992) or Schedule B (Form 8992) for that 
                                              necessary to complete Schedule B (Form       CFC must be the same.
Specific Instructions                         8992) and Form 8992, later.
                                                                                           Column (c).   Enter the U.S. dollar amount 
Form 8992                                     Part II                                      of tested income, if any, from line 6 of 
Use Form 8992 to compute the U.S.             For each line on Form 8992, Part II, follow  Schedule I-1 (Form 5471) for each CFC 
shareholder’s GILTI inclusion.                the instructions on the face of the form to  listed in column (a).
  Complete Form 8992 as follows.              determine the amount to enter on that line.  Column (d).   Enter the U.S. dollar amount 
• If the U.S. shareholder is not a member                                                  of tested loss, if any, from line 6 of 
of a U.S. consolidated group, use             Note.    If the amount on line 4 is greater  Schedule I-1 (Form 5471) for each CFC 
Schedule A (Form 8992), to determine the      than the amount on line 1, enter zero on     listed in column (a).
amounts to enter on Form 8992, Part l.        line 5.
                                                                                           Column (e).   Enter your pro rata share (as 
• If the U.S. shareholder is a member of a                                                 determined under Regulations section 
U.S. consolidated group, use Schedule B       For a corporate shareholder, enter the 
(Form 8992) to determine the amounts to       Part II, line 5, result on Form 1120,        1.951A-1(d)(2)) of the tested income listed 
enter on Form 8992, Part l.                   Schedule C, line 17, or on the comparable    in column (c).
                                              line of other corporate returns.             Column (f). Enter your pro rata share (as 
  Important: If completing Schedule B                                                      determined under Regulations section 
(Form 8992), see Steps necessary to           For an individual shareholder, enter the     1.951A-1(d)(4)) of the tested loss listed in 
complete Schedule B (Form 8992) and           Part II, line 5, result on Schedule 1 (Form  column (d).
Form 8992, later.                             1040), Part I, line 8n (Section 951A(a) 
                                              inclusion), or on the comparable line of     Important: See the instructions for 
Name Change                                   other noncorporate tax returns.              Form 8992, Part I, earlier, to determine if 
                                                                                           you are required to complete columns (g) 
If the name of the person filing the return                                                through (l).
changed within the past 3 years, include      Schedule A
the prior name in parentheses after the       In the case of a U.S. shareholder that is    Column (g).   Enter your pro rata share (as 
current name.                                 not a member of a U.S. consolidated          determined under Regulations section 
                                              group, the U.S. shareholder files            1.951A-1(d)(3)) of the U.S. dollar amount 
Item A. Identifying Number                    Schedule A (Form 8992), to report its pro    of QBAI from line 8 of Schedule I-1 (Form 
                                              rata share of amounts for each CFC (the      5471) for each tested income CFC.
The identifying number of an individual is    tax year of which ends with or within the 
the individual’s social security number       shareholder’s tax year) from each CFC’s      Note. If you have a tested loss for a 
(SSN). The identifying number of all others   Schedule I-1 (Form 5471), Information for    particular CFC, no entry should be made 
is their employer identification number       Global Intangible Low-Taxed Income, to       for that CFC in this column. See 
(EIN). In the case of a U.S. consolidated     determine the U.S. shareholder’s GILTI, if   Regulations section 1.951A-3(b).
group, list the common parent as the          any, and to determine the amount of the      Column (h).   Enter your pro rata share (as 
person filing the return and enter its EIN in U.S. shareholder’s GILTI, if any, allocated  determined under Regulations section 
item A.                                       to each CFC. If a U.S. shareholder does      1.951A-1(d)(3)) of the tested loss QBAI 
                                              not file a Schedule I-1 (Form 5471) for a    amount of any tested loss CFC. The 
Item B. Identifying Number                    CFC that is part of its GILTI computation,   tested loss QBAI amount of a tested loss 
If the name of the U.S. shareholder of the    for instance, due to an exception for        CFC is the amount reported on 
CFC(s) reported on this Form 8992 is          multiple filers of the same information, the Schedule I-1 (Form 5471), line 9c, that the 
different from the name of the person filing  U.S. shareholder will still need to provide  tested loss CFC would have had if it were 
this return, enter the U.S. shareholder’s     amounts with respect to each CFC as if       instead a tested income CFC. See 
identifying number. In the case of a U.S.     the U.S. shareholder filed Schedule I-1      Regulations sections 1.951A-4(b)(1)(i) 
consolidated group, leave the name of the     (Form 5471) for that CFC.                    and 1.951A-4(b)(1)(iv), and example 5 of 
U.S. shareholder and item B blank.                                                         Regulations section 1.951A-4(c)(5).
                                                       Due to space limitations, if you 
                                                       need to list more CFCs than fit on 
Part I                                        CAUTION! one Schedule A (Form 8992),         Column (i). Enter your pro rata share (as 
                                                                                           determined under Regulations section 
If the U.S. shareholder is not a member of    attach Schedule A—Continuation Sheet(s)      1.951A-1(d)(6)) of the amount of tested 
a U.S. consolidated group, to figure the      to continue listing the CFCs and their       interest income from Schedule I-1 (Form 
amounts to enter on lines 1 and 2, first      respective information. Do not write “See    5471), line 10c, for each CFC.
complete Schedule A (Form 8992),              attached” in the section and attach 
columns (a) through (f). See the specific     additional sheets.                           Column (j). Enter your pro rata share (as 
instructions for Schedule A, later. Then,                                                  determined under Regulations section 
follow the applicable instructions on the     Column (a). Enter the name of each           1.951A-1(d)(5)) of tested interest expense 
face of Form 8992, Part I, lines 1 through    CFC. If the name of any of the CFCs being    from Schedule l-1 (Form 5471), line 9d.
3, to determine the amounts to enter on       reported on Schedule A (Form 8992)           Column (k).   Before completing column 
each of those lines.                          changed within the past 3 years, include     (k), enter the totals (including amounts 
  If the amount on line 3 is greater than     the prior name(s) in parentheses after the   from any Schedule A—Continuation 
zero, complete Schedule A (Form 8992),        current name.                                Sheet(s)) of columns (c) through (j) on 

                                                                 -2-                       Instructions for Form 8992 (Rev. 12-2021)

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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.
with an amount in column (e), divide that                                                  a. If the Schedule B (Form 8992), 
                                               How to complete and file Schedule B 
amount by the total on line 1, column (e).                                                 line 1, total for Part I, column (h), equals or 
                                               (Form 8992) and Form 8992.      Complete 
Enter the result here to four decimal                                                      exceeds the line 1 total for Part I, column 
                                               a single Schedule B (Form 8992) for all 
places. See section 951A(f)(2).                                                            (g): Enter the amount from Schedule B 
                                               members of the U.S. consolidated group 
Column (l). For each CFC with an               that are U.S. shareholders of a CFC.        (Form 8992), Part I, line 1, column (g), on 
amount in column (e), multiply the column      Certain amounts from Schedule B (Form       Form 8992, Part I, line 1. Enter the amount 
(k) ratio for that CFC by the Form 8992,       8992) are carried over to the consolidated  from Schedule B, Part I, line 1, column (h), 
Part II, line 5, amount and enter the result   group’s Form(s) 8992. A separate Form       on Form 8992, Part I, line 2. Combine the 
in column (l) in whole dollars only. This      8992 is completed for each member of the    amounts shown on Form 8992, Part I, 
information is used in completing              consolidated group that is a U.S.           lines 1 and 2, and enter the result on Form 
Schedule J (Form 5471), Accumulated            shareholder of a CFC. Additionally, a       8992, Part I, line 3. Do not complete the 
Earnings and Profits (E&P) of CFC, and         consolidated Form 8992 is completed for     remainder of Form 8992. This is the 
Schedule P (Form 5471), Previously             the consolidated group as a whole. The      consolidated Form 8992 that will be filed 
Taxed Earnings and Profits of U.S.             Schedule B (Form 8992) and the              with the U.S. consolidated group’s income 
Shareholder of Certain Foreign                 consolidated Form 8992 are filed with the   tax return. Do not complete the remainder 
Corporations, for each CFC.                    consolidated group’s income tax return.     of the steps listed below.
                                               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 
On line 1 of the first completed page of                                                   than the line 1 total for Part I, column (g): 
Schedule A (Form 8992), enter the totals       Steps necessary to complete Sched-
for columns (c) through (f) for Schedule A     ule B (Form 8992) and Form 8992.            For each line of the Form 8992, aggregate 
                                                                                           the amounts from the corresponding line 
(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.                             4. Complete Schedule B (Form 8992), 
8992) the totals for columns (g) through (l)   b. Enter the totals for columns (e)         Part I, columns (o) and (p), using the 
for Schedule A (Form 8992) and any             through (h) on line 1 of those columns. In  instructions provided below.
Schedule A—Continuation Sheets.                doing so, please note that the total 
                                               amounts for Part I, columns (e) and (f)     Note. Do not file the Forms 8992 that 
Schedule B                                     should not reflect items from any CFC       were completed for each U.S. 
Purpose of schedule.  Use Schedule B           more than once, even if the CFC is listed   shareholder. Instead, keep them for your 
to report amounts used in determining the      more than once.                             records so that they are available upon 
GILTI inclusion amount of each member of       c. If the line 1 total for Part I, column   request (for example, in the case of an 
a consolidated group that is a U.S.            (h), equals or exceeds the line 1 total for examination).
shareholder of any CFC. In doing so,           Part I, column (g), do not complete the 
apply the rules of section 951A to each        remainder of Schedule B. Also, do not       Instructions for Part I
member in accordance with Regulations          complete the remainder of step 1 or any     Column (a), Name of CFC.    In column 
section 1.1502-51 as follows.                  portion of step 2. Proceed to step 3.       (a), list all CFCs, an interest in which is 
Use Part I to report relevant amounts          d. If the line 1 total for Part I, column   owned (within the meaning of section 
from Schedule I-1 (Form 5471) for each         (g), exceeds the line 1 total for Part I,   958(a)) by any member of the 
CFC owned (within the meaning of section       column (h), complete Part I, columns (i)    consolidated group. If more than one 
958(a)) by any member of the U.S.              through (n), using the instructions         member of the consolidated group owns 
consolidated group as well as the pro rata     provided below. Enter the totals for        (within the meaning of section 958(a)) an 
shares of such amounts for each member.        columns (i) through (n) on line 1 of those  interest in the same CFC, list the CFC on 
Use Part II to report the calculations         columns. In doing so, please note that the  multiple lines, using a separate line for 
necessary to determine the amounts that        total amounts for Part I, columns (k) and   each member that owns an interest in the 
will be carried over to the Form 8992 of       (m), should not reflect items from any CFC  CFC. Be sure to note the name and EIN of 
each member that is a U.S. shareholder in      more than once, even if the CFC is listed   the member that is a U.S. shareholder of 
order to determine that member’s GILTI         more than once.                             the CFC in columns (c) and (d). On each 
inclusion amount. See How to complete          e. Skip Part I, columns (o) and (p), for    line, enter the name of the CFC in column 
and file Schedule B (Form 8992) and            now. Do not complete Part I, columns (o)    (a). If the name of any of the CFCs being 
Form 8992 below.                               and (p), unless instructed to do so later.  reported on Schedule B (Form 8992) 
                                                                                           changed within the past 3 years, include 
Complete only one Schedule B (Form             f. Complete all columns of                  the prior name(s) in parentheses after the 
8992) for the U.S. consolidated group, and     Schedule B, Part II (columns (a) through    current name.
provide a copy to each member of the           (m)), using the instructions provided 
group.                                         below.                                      Column (b), EIN or reference ID num-
Computer-generated Schedule B.           A     2. Complete a separate Form 8992 for        ber of CFC. Please refer to the 
computer-generated Schedule B can be           each U.S. shareholder listed in             instructions for Form 5471, item 1b(2), 
filed if it conforms to the IRS version of the Schedule B (Form 8992), Part II, using the  Reference ID Number. Note that if a U.S. 
schedule. Expand Schedule B to properly        instructions provided on the face of Form   shareholder is required to file Schedule A 
complete Parts I and II of the schedule if     8992, to determine each U.S.                (Form 8992) or Schedule B (Form 8992) 
the number of CFCs and/or U.S.                 shareholder’s GILTI inclusion amount.       with respect to a CFC, the reference ID 
                                                                                           number on Form 5471 and the reference 

Instructions for Form 8992 (Rev. 12-2021)                            -3-

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ID number used on Schedule A (Form            there is a U.S. shareholder listed in        listed in column (c), multiply the GILTI 
8992) or Schedule B (Form 8992) for that      column (c) that owns an interest in a        allocation ratio for that CFC, listed in Part 
CFC must be the same.                         tested loss CFC listed in column (a) of that I, column (o), by the amount of the U.S. 
                                              line, enter the U.S. shareholder’s pro rata  shareholder’s GILTI inclusion amount (that 
Column (c), Name of U.S. shareholder. 
                                              share (as determined under Regulations       is, the amount shown on that U.S. 
For each CFC listed in column (a), enter in 
                                              section 1.951A-1(d)(3)) of the tested loss   shareholder’s Form 8992, Part II, line 5). 
column (c) the name of each U.S. 
                                              QBAI amount of the CFC. The tested loss      Enter the result in column (p) in whole 
shareholder that owns (within the meaning 
                                              QBAI amount of a tested loss CFC is an       dollars only.
of section 958(a)) an interest in that CFC.
                                              amount equal to 10% of the QBAI from 
                                                                                           Line 1. Enter on line 1 the totals for Part I, 
Column (d), EIN of U.S. shareholder.          Schedule I-1 (Form 5471), line 9c, that the 
                                                                                           columns (e) through (p).
For each U.S. shareholder listed in column    tested loss CFC would have had if it were 
(c), enter the EIN of the U.S. shareholder.   instead a tested income CFC. See             Note. The total amounts for Part I, 
Column (e), Tested Income.        For each    Regulations sections 1.951A-4(b)(1)(i)       columns (e), (f), (k), and (m) should not 
CFC listed in column (a), enter the U.S.      and 1.951A-4(b)(1)(iv), and example 5 of     reflect items from an CFC more than once, 
dollar amount of tested income, if any,       Regulations section 1.951A-4(c)(5).          even if the CFC is listed more than once.
from line 6 of Schedule I-1 (Form 5471).      Column (k), Tested interest expense. 
                                              For each CFC listed in column (a), enter     Instructions for Part II
Note. For each CFC listed in column (a),      the U.S. dollar amount of tested interest 
enter the column (e) amount on the            expense, if any, from Schedule I-1 (Form     Column (a), Name of U.S. shareholder. 
corresponding line of the U.S.                5471), line 9d.                              For each U.S. shareholder listed in Part I, 
shareholder's applicable Form 1118,                                                        column (c), enter in Part II, column (a), the 
Schedule D, Part I, column 6, for that CFC    Column (l), Pro rata share of tested in-     name of each such shareholder, using a 
(that is, the Form 1118 that is being         terest expense.  For each CFC listed in      single line for each such U.S. shareholder.
completed for passive category income or      column (a) and the U.S. shareholder listed 
general category income, as applicable).      in column (c), enter the U.S. shareholder's  Column (b), EIN of U.S. shareholder. 
                                              pro rata share (as determined under          Enter the EIN of each U.S. shareholder 
Column (f), Tested loss.  For each CFC        Regulations section 1.951A-1(d)(5)) of the   listed in Part II, column (a).
listed in column (a), enter the U.S. dollar   CFC's tested interest expense listed in      Column (c), Aggregate tested income. 
amount of tested loss, if any, from line 6 of column (k).                                  For each U.S. shareholder listed in Part II, 
Schedule I-1 (Form 5471).                                                                  column (a), enter the sum of all amounts 
                                              Column (m), Tested interest income. 
Column (g), Pro rata share of tested in-      For each CFC listed in column (a), enter     entered in Part I, column (g), with respect 
come. For each CFC listed in column (a)       the U.S. dollar amount of tested interest    to that U.S. shareholder. In other words, in 
and the U.S. shareholder listed in column     income, if any, from Schedule I-1 (Form      Part II, column (c), sort and then sum the 
(c), enter the U.S. shareholder's pro rata    5471), line 10c.                             pro rata share of tested income amounts 
share (as determined under Regulations                                                     listed in Part I, column (g), by U.S. 
section 1.951A-1(d)(2)) of the CFC's          Column (n), Pro rata share of tested in-     shareholder. See Regulations section 
tested income listed in column (e).           terest income.   For each CFC listed in      1.1502-51(e)(1).
                                              column (a) and the U.S. shareholder listed 
Note. For each CFC listed in column (a),      in column (c), enter the U.S. shareholder's  Note. Each U.S. shareholder listed in Part 
enter the column (g) amount on the            pro rata share (as determined under          II, column (a), will enter their Part II, 
corresponding line of the U.S.                Regulations section 1.951A-1(d)(6)) of the   column (c), amount on their Form 8992, 
shareholder's applicable Form 1118,           CFC's tested interest income listed in       Part I, line 1.
Schedule D, Part I, column 5, for that CFC    column (m).
                                                                                           Column (d), GILTI allocation ratio.       For 
(that is, the Form 1118 that is being         Columns (o) and (p). As explained in         each U.S. shareholder listed in Part II, 
completed for passive category income or      Steps necessary to complete Schedule B       column (a), divide the column (c) amount 
general category income, as applicable).      (Form 8992) and Form 8992, earlier,          for that U.S. shareholder by the total 
Column (h), Pro rata share of tested          Schedule B, Part I, columns (o) and (p),     amount shown on Part II, line 2, column 
loss. For each CFC listed in column (a)       are completed only after Form 8992 has       (c). See Regulations section 1.1502-51(e)
and the U.S. shareholder listed in column     been completed. Also, Schedule B, Part I,    (10).
(c), enter the U.S. shareholder's pro rata    columns (o) and (p), are completed only 
share (as determined under Regulations        with respect to tested income CFCs (that     Note. The GILTI allocation ratio 
section 1.951A-1(d)(4)) of the CFC's          is, those CFCs with a positive amount in     computed here in Part II, column (d), 
tested loss listed in column (f).             Schedule B, Part I, column (e)).             accords with the rules of Regulations 
                                                                                           section 1.1502-51(e)(10), and differs from 
Column (i), Pro rata share of QBAI.     For   Column (o), GILTI allocation ratio.          the GILTI allocation ratio computed in Part 
each tested income CFC listed in column       For each CFC listed in Schedule B, Part I,   I, column (o), which accords with the rules 
(a) and the U.S. shareholder listed in        column (a), that has an amount in            of section 951A(f)(2).
column (c), enter the U.S. shareholder’s      Schedule B, Part I, column (e), and the 
pro rata share (as determined under           U.S. shareholder listed in column (c),       Column (e), Aggregate tested loss. 
Regulations section 1.951A-1(d)(3)) of the    divide the Part I, column (g), amount for    For each U.S. shareholder listed in Part II, 
tested income CFC’s QBAI from line 8 of       that U.S. shareholder by the Part II,        column (a), enter the sum of all amounts 
that CFC’s Schedule I-1 (Form 5471).          column (c), amount for that U.S.             entered in Part I, column (h), with respect 
                                              shareholder. Enter the result to four        to that U.S. shareholder. In other words, in 
Note. If you have a tested loss for a         decimal places. See section 951A(f)(2).      Part II, column (e), sort and then sum the 
particular CFC, no entry should be made                                                    pro rata share of tested loss amounts 
for that CFC in Part I, column (i). See       Column (p), GILTI allocated to               listed in Part I, column (h), by U.S. 
Regulations section 1.951A-3(b).              tested income CFCs.  For each CFC            shareholder. See Regulations section 
                                              listed in Schedule B, Part I, column (a),    1.1502-51(e)(2).
Column (j), Pro rata share of tested          that has an amount in Schedule B, Part I, 
loss QBAI amount. For each line where         column (e), and the U.S. shareholder 

                                                               -4-                        Instructions for Form 8992 (Rev. 12-2021)

Page 5 of 5         Fileid: … ns/i8992/202112/a/xml/cycle05/source                                    16:50 - 8-Nov-2021

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

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

Instructions for Form 8992 (Rev. 12-2021)                          -5-