Foreign Corporation Analyser
Classify your foreign company ownership — CFC, PFIC, or neither — and calculate Subpart F income, GILTI inclusions, and Form 5471 requirements.
Ownership Structure
All US persons combined
Income Composition
Corp Type (Self-Select)
🏭 Trading / Operating
Active business earning trading income
💼 Holding Company
Holds investments, real estate, IP
🖥️ Services / Consulting
Personal service company
📈 Investment Fund
Foreign fund or pooled vehicle
Classification & Tax Impact
Awaiting analysis...
$0
Subpart F Income
$0
GILTI Inclusion
$0
US Tax Due
Your share of revenue
Subpart F (passive) income$0
GILTI inclusion (net of QBAI)$0
Foreign tax credit (80% of foreign tax)$0
Net US tax liability$0
Filing Requirements
GILTI High-Tax Exclusion (2021 Regs)
If the effective foreign tax rate on GILTI is ≥90% of the US corporate rate (21% × 90% = 18.9%), the GILTI high-tax exclusion may apply, eliminating the GILTI inclusion. Individual CFC owners (non-corporate) do NOT benefit from the §250 deduction — 100% of GILTI is taxable at ordinary rates with only 80% of foreign taxes creditable.
Complex CFC/PFIC Planning
Foreign corporation structuring requires specialist US international tax counsel.
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