is the USSH's pro rata share of the average adjusted basis of U.S.
USSH and includes an adjustment to account for previously taxed income,
is the full amount that must be added to the USSH's gross income to
GILTI is determined using the same definitions of USSH and CFC, the same
GILTI's inclusion in a USSH's gross income only applies if the
CFC, GILTI is determined at the level of the USSH and includes income
from all of the CFCs for which the corporation is a USSH. (92) As
regulatory guidance, GILTI must be calculated for every USSH within an
general, GILTI is the USSH's net CFC tested income ("Net CFC
tax, is calculated at the level of the USSH and includes income from
multiple CFCs when the parent corporation is a USSH of multiple CFCs.
tested loss for each CFC for which the corporation is a USSH. (96) The