GILTI Inclusion

GILTI (Global Intangible Low-Taxed Income) is a U.S. tax rule that taxes a portion of a multinational company's foreign earnings. It encourages U.S. companies to pay a minimum level of tax on income earned abroad, especially from intangible assets like patents or trademarks. When a U.S. company owns foreign subsidiaries, GILTI ensures they can't avoid U.S. taxes by shifting profits to low-tax jurisdictions. Essentially, it brings some of the foreign income back into the U.S. for tax purposes, promoting fair taxation and discouraging profit shifting.