Statute section
IRC section 951A
Global intangible low-taxed income (GILTI)
Country
United States
Section
951A
Updated
2026-05-20
Operative text
Section 951A includes global intangible low-taxed income (GILTI) in the gross income of U.S. shareholders of a controlled foreign corporation. GILTI generally equals net CFC tested income above a 10-percent return on qualified business asset investment (QBAI). Section 250 provides a partial deduction for corporate U.S. shareholders.
Amendment history
2017-12-22
Pub. L. 115-97
TCJA enacted Section 951A as part of the territorial-tax overhaul.
Cross-references
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This entry cites
- StatuteIRC §951
Cited by
Primary sources
- 26 U.S.C. section 951AVerified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.