Hello fellow tax preparers !
I have a client with 42 different CFC, the tested losses exceed the tested income, but one of the CFC had income, had E & P, and the US 100 shareholder took a distribution to the amount of the income.
The form 8992 line 3 says there is no GILTI income to report since the combined tested income and tested loss is negative.
1. Since the combined GILTI is negative do I have to report the distribution as a dividend? and I am thinking if it is a dividend, it is not qualified.
2. Do I report this distribution as a dividend on schedule B or under Other Income 951A.
Thanks for your comments !!!
Art