GILTI is a tax applied to the revenue of non-U.S. companies, or Controlled Foreign Corporations, that are controlled by U.S. corporations and citizens.

To neutralize that incentive, in addition to retaining subpart F rules (which are discussed in other Practice Units), the TCJA also enacted the GILTI rules, which require U.S. shareholders of controlled …

Sep 1, 2025 · GILTI, or Global Intangible Low-Taxed Income, is a tax on certain foreign earnings of U.S. multinational corporations. Its purpose is to act as an anti-base erosion measure, discouraging …

The main priority for GILTI is to ensure U.S. shareholders of Controlled Foreign Corporations (CFCs) are paying necessary tax on certain income generated from foreign businesses — even if it is not …

May 22, 2025 · GILTI, short for Global Intangible Low-Taxed Income, is a tax applied to the tested income of controlled foreign corporations (CFCs) owned by US corporations and citizens.

Nov 3, 2025 · The GILTI/NCTI high-tax exception is a provision that allows certain income of a CFC to be excluded from current U.S. tax if it is subject to a high rate of foreign tax.

Jul 24, 2025 · GILTI stands for Global Intangible Low-Taxed Income. It was introduced by the U.S. Tax Cuts and Jobs Act of 2017 as part of a broader effort to prevent U.S. taxpayers from shifting profits to …

Dec 17, 2025 · What is the GILTI tax, and why should businesses care? The Global Intangible Low-Taxed Income (GILTI) tax impacts multinational corporations by taxing income from foreign …

So, in the 2017 tax bill, Congress added a new 10.5 percent minimum tax on global intangible low-taxed income (GILTI) to discourage such profit shifting. GILTI is intended to approximate the income from …

This new provision, addressing the treatment of global intangible low-taxed income (GILTI), presents a substantial shift in the U.S. taxation of foreign earning. If GILTI rules apply, a U.S. shareholder must …