Section 951A

Section 951A of the U.S. Internal Revenue Code introduces the concept of "Global Intangible Low-Taxed Income" (GILTI). It targets U.S. companies with foreign subsidiaries, requiring them to include certain foreign earnings on their U.S. tax returns, specifically earnings that are not taxed at a high rate. This provision aims to curb tax avoidance by ensuring that profits made abroad are subject to U.S. taxation, promoting fairness among domestic and foreign operations. Essentially, it prevents companies from taking advantage of lower tax rates in other countries while still benefiting from access to the U.S. market.