8992 Sch. A

Schedule of Controlled Foreign Corporation (CFC) Information to Compute Global Intangible Low-Taxed Income (GILTI)

Agency
IRS
Revision
Rev. December 2022
Fillable fields
268
Pages
2
Official source
IRS form page
Checked
October 21, 2026
Fill 8992 Sch. A online
Page 1 of form 8992 Sch. A

Schedule A (Form 8992): CFC Information To Compute Global Intangible Low-Taxed Income

Schedule A (Form 8992), Schedule of Controlled Foreign Corporation (CFC) Information To Compute Global Intangible Low-Taxed Income (GILTI), is a two-page schedule with ten rows for CFCs on page 1 and a continuation sheet on page 2. The Instructions for Form 8992 say a U.S. shareholder that is not a member of a U.S. consolidated group files it to report its pro rata share of amounts for each CFC from that CFC's Schedule I-1 (Form 5471), to determine its GILTI inclusion amount, if any, and how much of that amount is allocated to each CFC.

The instructions say Schedule A is generally completed and attached to Form 8992. A member of a U.S. consolidated group completes Schedule B (Form 8992) instead. Columns (a) through (f) feed Form 8992, Part I. Columns (g) through (l) are completed only when Form 8992, Part I, line 3 is greater than zero.

This page hosts the December 2022 revision, used with the Instructions for Form 8992. You can fill out Schedule A free in your browser on this page and download it without an account.

What's on Schedule A (Form 8992)

Header

The name of the person filing the schedule with its identifying number in item A, and the name of the U.S. shareholder with its identifying number in item B.

Columns (a) and (b): the CFC

The name of each CFC and its EIN or reference ID number.

Columns (c) through (f): net tested income

Each CFC's tested income and tested loss, then the shareholder's pro rata share of each, under the heading Calculations for Net Tested Income.

Columns (g) through (j)

Pro rata shares of qualified business asset investment (QBAI), the tested loss QBAI amount, tested interest income and tested interest expense.

Columns (k) and (l): GILTI allocation

Column (k) is the GILTI allocation ratio, column (e) divided by the column (e) total on line 1. Column (l) multiplies Form 8992, Part II, line 5 by column (k).

Line 1 and the continuation sheet

Line 1 holds the totals, including totals from any continuation sheets. Page 2 is the Schedule A Continuation Sheet, used only when more space is needed.

How to fill out Schedule A (Form 8992)

  1. 1

    Header

    Enter the filer's name and identifying number in item A. The Form 8992 instructions say an individual's identifying number is the SSN and all others use the EIN. If the U.S. shareholder is a different person, enter its name and number in item B.

  2. 2

    Columns (a) and (b)

    List each CFC, with any prior names from the past 3 years in parentheses. Enter the CFC's EIN, or a reference ID number if it has none. The instructions say not to enter "APPLIED FOR" or "FOREIGNUS" in column (b).

  3. 3

    Columns (c) through (f)

    Enter the U.S. dollar amount of tested income or tested loss from line 6 of the CFC's Schedule I-1 (Form 5471), then the shareholder's pro rata share of each.

  4. 4

    Totals and Form 8992, Part I

    Enter the column totals on line 1 and complete Form 8992, Part I. The instructions say that if Part I, line 3 is zero or negative, columns (g) through (l) and Form 8992, Part II are not completed.

  5. 5

    Columns (g) through (j)

    Enter pro rata shares of QBAI from Schedule I-1, line 8 for each tested income CFC, the tested loss QBAI amount from line 9c, tested interest income from line 10c and tested interest expense from line 9d.

  6. 6

    Columns (k) and (l)

    After Form 8992, Parts I and II are done, divide each CFC's column (e) amount by the line 1, column (e) total, to four decimal places. Multiply that ratio by Form 8992, Part II, line 5 and enter whole dollars in column (l).

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Where it goes, timing and corrections

Attach to Form 8992

The instructions say to attach Form 8992 and Schedule A to the income tax return, or exempt organization return, and file both by the due date (including extensions) for that return.

Continuation sheets

If more CFCs need listing, attach Schedule A Continuation Sheets. The instructions say not to write "See attached" on Schedule A and attach other sheets.

Reference ID numbers

The instructions say the reference ID number used for a CFC on Schedule A and on Form 5471 must be the same.

Where column (l) is used

The instructions say the column (l) amounts are used in completing Schedule J (Form 5471) and Schedule P (Form 5471) for each CFC.

Corrections

A corrected Form 8992 is filed with an amended return. The instructions say to write "Corrected" at the top and attach a statement identifying the changes.

Penalties

The instructions say penalties under sections 6038(b) and (c) may apply for failure to report the information required.

Who files Schedule A (Form 8992)?

  • U.S. shareholders of CFCs

    The instructions define a U.S. shareholder as a U.S. person who owns 10% or more of the total combined voting power of all classes of voting stock, or 10% or more of the total value of shares of all classes of stock, of a foreign corporation.

  • Individuals and corporations

    The instructions say a corporate shareholder enters the Form 8992, Part II, line 5 result on Form 1120, Schedule C, line 17, and an individual shareholder enters it on Schedule 1 (Form 1040), line 8o.

  • S corporations that elected entity treatment

    An S corporation that elected under Proposed Regulations section 1.958-1(e) to be treated as owning CFC stock, and is a U.S. shareholder of a CFC, completes Form 8992 and Schedule A and attaches them to its Form 1120-S.

  • Not for consolidated groups

    A member of a U.S. consolidated group uses Schedule B (Form 8992) instead. The instructions say one consolidated Form 8992 is filed with the group's income tax return.

  • Not for domestic partnerships

    The instructions say domestic partnerships are no longer required to complete Form 8992 or Schedule A. They complete Schedule K-2 (Form 1065), Part VI, and Schedule K-3 (Form 1065), Part VI, instead.

The instructions say a U.S. shareholder that is not a member of a U.S. consolidated group files Schedule A with Form 8992. The schedule reports amounts for each CFC whose tax year ends with or within the shareholder's tax year.

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Questions about Form 8992 Sch. A

When is Schedule B used instead of Schedule A?

The instructions say a U.S. shareholder that is a member of a U.S. consolidated group completes Schedule B (Form 8992). Other U.S. shareholders generally use Schedule A.

Where do the amounts on Schedule A come from?

From each CFC's Schedule I-1 (Form 5471), lines 6, 8, 9c, 9d and 10c. The instructions say a shareholder that does not file Schedule I-1 for a CFC still provides the amounts as if it had.

Are columns (g) through (l) always completed?

No. The instructions say they are completed only when Form 8992, Part I, line 3 is greater than zero.

What if there are more than ten CFCs?

Use the continuation sheet on page 2. The form says the line 1 totals on page 1 include the totals from any continuation sheets.

Do domestic partnerships file Schedule A?

The instructions say domestic partnerships no longer complete Form 8992 or Schedule A. They complete Part VI of Schedules K-2 and K-3 (Form 1065) instead.