Global Intangible Low-Taxed Income (GILTI)

Definition

Section 951A includes GILTI in U.S. shareholder gross income equal to net CFC tested income above 10 percent of qualified business asset investment (QBAI). Corporate U.S. shareholders are entitled to a partial Section 250 deduction.

Examples

• A U.S. parent with a profitable foreign IP-rich subsidiary will likely have substantial GILTI inclusion.