S Corp Owner |
C Corp Owner |
|
GILTI |
$ 1,000 |
$ 1,000 |
Gross-up |
N / A |
200 |
GILTI deduction ( 28.5 % under BBB ) |
N / A |
( 285 ) |
Taxable Income |
1,000 |
915 |
Entity tax |
N / A |
192 |
Foreign tax credit ( 95 % X foreign tax ) |
N / A |
190 |
Net entity tax |
0 |
2 |
Shareholder tax on foreign income |
350 |
N / A |
NIT on foreign income |
38 |
N / A |
Distribution to shareholder |
1,000 |
998 |
Tax on distribution ( 20 % + 3.8 % NIT ) |
0 |
238 |