If GILTI inclusion is reduced by GILTI reduction to zero because taxable income is a loss (excess GILTI over taxable income) is the GILTI deduction still 50% of gross up of taxes for GILTI? This did not seem to be the case for 2018 returns.
2019 Instructions state subtract GILTI reduction from GILTI inclusion. Then add any amount received by the corporation that is treated as a dividend under section 78 which is attributable to GILTI from Form 1118 and multiply that amount by 50%. I cannot find anything specific under section 250 regs.
Thanks.