The ABC Company is a U.S. based MNC. It has active business operations around the world. It operates outside the U.S. through non-U.S. based subsidiaries.

In 2023, non-U.S. based subsidiaries generated Tested income for GILTI purposes of $8 billion dollars. It did not pay any non-U.S. tax in relation to this income.

In 2023, ABC had quarterly average adjusted tangible property for GILTI purposes of $1 billion dollars.

ABCs U.S. tax rate was 21%

A. How much GILTI tax will ABC have to pay in the U.S. in relation to 2023s tested income?

B. Holding tested income at $8 billion, what average adjusted tangible property investment would eliminate ABCs GILTI tax?

C. Given the above, how much would ABC have to have paid in foreign taxes to eliminate any U.S. tax in relation to GILTI income in 2023?

D. Assume ABC has an infinite amount of FTCs in 2023. Does ABC have an incentive to use as many of these FTCs as possible in 2023?

YES NO

E. Assume ABC has an infinite amount of NOLs generated after 12/31/2017. Does ABC have an incentive to use these NOLs as possible in 2023?

YES NO