U.S. citizens and U.S. residents who are officers, directors, or shareholders in certain foreign corporations are responsible for IRS Form 5471 filing.
Under the TCJA, rules requiring the inclusion of GILTI for controlled foreign corporations (CFCs) were added. The new rules are in Section 951A and other sections of the Internal Revenue Code (IRC). The inclusion aims to tax U.S. shareholders on their allocable share of earnings from a CFC. This is to the extent that the earnings exceed a 10% return on tangible assets allocated to the U.S. shareholder.