GILTI, Subpart F & BEATAnswered

My foreign company made profit but paid me nothing. Can I still have GILTI on Form 8992?

VC
victor_c8c8subscriber
December 16, 2025 2,057 views 1 answer
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I am a U.S. individual shareholder of a foreign company that retained all earnings this year to fund growth. There were no dividends, no shareholder loans, and no personal withdrawals. That made me assume I would not have a U.S. tax inclusion until cash actually came out.

Then Form 8992 and GILTI entered the conversation, and now it sounds like the U.S. inclusion might happen regardless of distributions. If that is true, I need to stop thinking about the company like a domestic startup where tax follows actual cash payments.

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