GILTI Foreign Income 2027

GILTI: tested income - QBAI × 10%. Tax: 21% × 50% deduction (37(k)) = 10.5% effective. Plus FTC offset up to 80%.

GILTI Inclusion
Net GILTI Tax
Effective Rate
CFC tested income
QBAI
QBAI 10% exemption
GILTI inclusion
Section 250 deduction (50%)
Taxable GILTI
21% tax (pre-FTC)
Foreign tax paid
FTC available (80%)
Net GILTI tax
Effective rate
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GILTI (Global Intangible Low-Taxed Income) is a US corporate tax on income earned by Controlled Foreign Corporations (CFCs). Designed by TCJA to discourage profit-shifting overseas. Effective rate: 10.5% (21% × 50% deduction). Major change in 2027 — may rise per OBBB provisions.

Calculation Mechanics

Tested income = net income of CFC (excluding Subpart F and certain other items). QBAI = qualified business asset investment (depreciable property). Exempt 10% of QBAI. Remainder is GILTI inclusion to US shareholder. Then 50% deduction (Section 250) + 80% FTC.

Section 250 Deduction

50% deduction on GILTI inclusion makes effective rate 10.5% (vs full 21%). Subject to taxable income limitation. For tax years 2026+, deduction drops to 37.5%, making effective rate 13.125%. OBBB may modify further — monitor for changes.

Foreign Tax Credit Offset

Only 80% of foreign tax paid usable as FTC against GILTI. Encourages locating in higher-tax foreign jurisdictions (UK, DE) since FTC fully offsets US tax. Discourages tax havens (BVI, Cayman) where minimal foreign tax = minimal FTC offset.

Last updated May 2026. Sources: IRS GILTI Resources.