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Federal GILTI Adjustments for Electing Individuals, Trusts and Estates
Income Tax Guidance on Global Intangible Low-Taxed Income GILTI For Corporations, Individuals, Trusts, and Estates
Federal GILTI Adjustments for Electing Individuals, Trusts and Estates
Generally, individuals, trusts and estates include GILTI in gross income without adjustments under IRC 78 and IRC 250. However, an individual, trust or estate may elect to pay a tax equal to a U.S. corporation’s on GILTI under IRC 962(a)(1) and 951A(f).10 If the federal election is made, these taxpayers also apply the corporate adjustments for IRC 7811 and IRC 250(a)(1)(B).12
10Trusts and estates may make an IRC 962(a)(1) election under Treas. Reg. 1.962-2(a).
11Treas. Reg. 1.962-1(b)(1)(i)(B)(3).
1284 FR 8200 (March 6, 2019).