Page 659 - Large Business IRS Training Guides

GILTI
Inclusions for Corporate US Shareholders

generally taxed at an effective tax rate
• The GILTI inclusion is
(before FTCs)
of at most 10.5% (13.125% beginning in 2026)
because corporate US shareholders
are generally entitled to a
deduction equal to 50% of the GILTI inclusion (37.5% beginning

under § 250.
in 2026)

• They are deemed to have paid 80%
of the foreign income taxes

paid/accrued by
the CFC with respect to the CFC’s tested
income that results in the US shareholder’s GILTI.

• GILTI of the US
shareholder is generally in the GILTI category
for FTC purposes
(with no FTC carryover or carryback).

“grossed up” under § 78 to include 100%
• The GILTI inclusion is
of the taxes
deemed paid with respect to GILTI.

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