Form 8992

[Taxfun]

CFC 1with a tested loss.  husband owns 10%, wife owns 90%

CFC 2 with a tested income.  wife owns 100%.

Husband and wife files a joint tax return.

GILTI looks at directly and indirectly ownership. And family member considered as a constructive ownership. So constructively, husband owns CFC 2, however, from GILTI aspect, husband does not have any GILTI income from CFC 2.

so question, can husband and wife files a combined form 8992? in that case, all the tested income from CFC2, will be offset by all the tested loss from CFC 1. or husband and wife should file a separate form 8992, to include each share of tested income/loss of directly or indirectly ownership?

thanks!