Page 190 - International Taxation IRS Training Guides

GILTI Income
Inclusion and Deduction

 GILTI
amount included currently in US shareholder’s
income

are generally allowed a
 Corporate US shareholders
to 50% of GILTI and IRC 78 gross-up
deduction equal

to GILTI for 2018-2025 (37.5% of GILTI
with respect

starting in 2026)

 Individual US
shareholders not allowed deduction

can elect under IRC 962 to be subject to tax at
• US individuals
under proposed regulations.
corporate rates, including on GILTI
shareholders are still subject to tax at
Electing US individual
rates when earnings are distributed.
individual

 Deduction discussed further
in next section

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