How do you calculate GILTI? What are tested income, QBAI, and net DTIR?
I understand GILTI at a high level but I'm struggling with the actual calculation. My CPA mentioned terms like 'tested income,' 'QBAI,' and 'net deemed tangible income return' and I got lost. I own a U.S. holding company that has two CFCs — one is profitable and the other is running at a loss. Can someone walk me through the mechanics of how GILTI is actually computed? And does the loss from one CFC offset the income from the other?
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