Page 194 - International Taxation IRS Training Guides

Deduction for
GILTI and Foreign-Derived

Intangible
Income, or FDII

IRC 250, which provides corporate
 TCJA enacted new
on the sum of GILTI and FDII subject to a
deductions

taxable income limitation

 Purpose of
GILTI Deduction: To avoid a negative

impact on the competitiveness of
US multinationals
relative to their foreign peers
from taxing the GILTI

the full US tax rate, TCJA provides
inclusion amount at
and the related
a 50% deduction with respect to GILTI

IRC 78 gross-up with respect to GILTI

• 50%
of GILTI for 2018-2025, 37.5% of GILTI starting in 2026

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