What is GILTI tax?
GILTI taxes US shareholders on intangible income earned by their foreign corporations. Learn the rules, Section 250 deduction, and how individuals can mitigate it.
GILTI — Global Intangible Low-Taxed Income — is a US tax regime that forces individual shareholders of CFCs to pay US tax on certain foreign corporate earnings. For 2026, US individual shareholders generally cannot claim the Section 250 deduction that corporations enjoy, which means GILTI is taxed at your full ordinary income rate. You may be able to make a Section 962 election to be taxed as a corporation and claim the 50% deduction, reducing the effective rate. GILTI is reported on Form 8992 and flows through to your individual return. If you own a foreign operating business, plan carefully — GILTI can create tax liability even when no cash is distributed to you.