Use Part V to determine your subpart F income inclusions
and section 951(a)(1)(B) inclusions, or your share of the S
corporation’s subpart F income inclusions and section 951(a)
(1)(B) inclusions, and to complete Form 8992.
If the S corporation has made an election to be treated as
owning stock of a foreign corporation within the meaning of
section 958(a) under Proposed Regulations section
1.958-1(e)(2), and is a U.S. shareholder of the foreign
corporation during a tax year of the foreign corporation, then
any subpart F income inclusions and section 951(a)(1)(B)
inclusions with respect to the foreign corporation for such tax
year are inclusions of the S corporation, of which you
generally include a share in gross income. In such a case,
your share of the S corporation’s subpart F income inclusions
and section 951(a)(1)(B) inclusions are reported on
Schedule K-1, line 10, Other income (loss), and are not
reported in Part V.
If the S corporation has not made an election to be treated
as owning stock of a foreign corporation within the meaning
of section 958(a) under Proposed Regulations section
1.958-1(e)(2); and is a U.S. shareholder of the foreign
corporation during such tax year, then any subpart F income
inclusions and section 951(a)(1)(B) inclusions with respect to
a foreign corporation for such a tax year are inclusions of the
S corporation, of which you generally include a share in gross
income. In such case, your share of the S corporation’s
subpart F income inclusions and section 951(a)(1)(B)
inclusions are reported on Schedule K-1, line 10, “Other
income (loss),” and are not reported in Part V.
If the S corporation elected to be treated as owning stock
of a foreign corporation within the meaning of section 958(a)
under Proposed Regulations section 1.958-1(e)(2), and the S
corporation is a U.S. shareholder of the foreign corporation
during a tax year of the foreign corporation, the S corporation
determines its section 951A inclusion for its tax year in which
or with which such tax year of the foreign corporation ends, of
which you generally include a share in gross income . In such
a case, your share of the S corporation’s section 951A
inclusion is reported on Schedule K-1, line 10, “Other income
(loss),” and is not reported in Part V.
For each CFC listed in column (a) of which you are a U.S.
shareholder, include the amounts of subpart F income and
section 951(a)(1)(B) inclusion reported in Part V in
determining the amount you report on Schedule 1 (Form
1040), line 8.
For each CFC listed in column (a) of which you are a U.S.
shareholder, report the tested income and tested loss for
each CFC in Schedule A (Form 8992), Schedule of
Controlled Foreign Corporation (CFC) Information To
Compute Global Intangible Low-Taxed Income (GILTI),
columns (c) and (d), respectively, and include your share of
each CFC’s items described in columns (i) through (n) in
determining the amount to report in Schedule A (Form 8992),
columns (e) through (j), respectively.
