GILTI Tax Calculator
GILTI (Global Intangible Low-Taxed Income) is a US tax on foreign subsidiary income above a 10% return on tangible assets. Calculate GILTI inclusion, Section 250 deduction, and effective tax rate.
| Foreign tested income | — |
| QBAI × 10% (return on tangible assets) | — |
| GILTI inclusion (tested income − 10% QBAI) | — |
| Section 250 deduction (50% for C-corp) | — |
| Net GILTI subject to US tax | — |
| US tax on GILTI | — |
| Foreign tax credit (80% of foreign tax) | — |
| Net US tax owed on GILTI | — |
| Effective tax rate on GILTI | — |
GILTI (Global Intangible Low-Taxed Income) is a US tax under IRC §951A on the foreign subsidiary income of US shareholders above a 10% deemed return on tangible business assets. Created in 2017 to discourage US multinationals from shifting intangible income (IP, software) to low-tax jurisdictions. OBBB extended the Section 250 50% deduction through 2028.
How GILTI Is Calculated
(1) Tested income: foreign subsidiary's net income excluding subpart F income, dividends, related-party transactions. (2) QBAI: Qualified Business Asset Investment — book value of tangible depreciable assets. (3) GILTI inclusion: Tested income − 10% × QBAI. (4) Section 250 deduction: 50% (C-corps only). (5) US tax: at corporate rate (21%) for C-corps; ordinary individual rates for pass-through.
Why C-Corps Win
C-corps get Section 250 deduction (50% reduces GILTI tax base by half) + 80% of foreign tax credit. Effective rate typically 10.5% (21% × 50%) before FTC, often 0% after FTC if foreign tax rate is reasonable. Individuals get NO Section 250 deduction and NO direct FTC for GILTI — pay ordinary rates. Many individuals make IRC §962 election to be taxed as if they received GILTI via a C-corp.
OBBB Changes
OBBB (P.L. 119-21) extended the Section 250 50% deduction through 2028. Was scheduled to drop to 37.5% in 2026. Also retained the 80% FTC limitation for GILTI (no carryforward, no carryback). Foreign tax rate must average around 13% for C-corp to fully offset GILTI tax.
Last updated May 2026. Sources: IRS GILTI Overview, IRS Form 8992 (GILTI).