Page 184 - International Taxation IRS Training Guides

Global Intangible
Low-Taxed Income,

or GILTI

 Introduction of
a new participation exemption system
without base protection measures
could incentivize

to allocate income to CFCs operating in low-
taxpayers

or zero-tax jurisdictions
tax

retained full and immediate taxation of certain
 TCJA
passive and mobile CFC
income (subpart F income)

 TCJA enacts new
IRC 951A, known as GILTI, to

subject
other CFC income to current taxation

 TCJA also enacted a deduction for
certain US

shareholders
to reduce the rate of tax on GILTI

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