What is the effective GILTI tax rate under current law?

Under TCJA: 21% × (1 − 50% deduction) = 10.5% rate before FTCs. An 80% foreign tax credit applies, creating a 10.5% effective rate if the foreign rate is 0%. Pillar Two minimum tax of 15% creates additional top-up tax above GILTI for most MNEs.

What is the QBAI exclusion in GILTI?

QBAI (Qualified Business Asset Investment) exclusion removes 10% of net tangible income-producing assets from the GILTI base. Companies with large tangible assets (manufacturing) have lower GILTI than IP-holding companies with minimal QBAI.

GILTI Effective Free Online Calculator and Tools

How It Works

Calculate the effective US tax rate on GILTI (Global Intangible Low-Taxed Income) from a US parent's controlled foreign corporations, including the 50% deduction (TCJA), 80% FTC, and QBAI (10% routine return exclusion)

Each component has a specific meaning:

US parent's controlled foreign corporations — The us parent's controlled foreign corporations recorded for the scenario being assessed.
Including the 50% deduction — The including the 50% deduction recorded for the scenario being assessed.
80% FTC — The 80% ftc recorded for the scenario being assessed.
QBAI — The qbai recorded for the scenario being assessed.

Note: Interpret the gilti etr result against the thresholds and context described above.

How to Use

Enter the US parent's controlled foreign corporations, including the 50% deduction, 80% FTC, QBAI for the scenario you are assessing. Calculate the effective US tax rate on GILTI (Global Intangible Low-Taxed Income) from a US parent's controlled foreign corporations, including the 50% deduction (TCJA), 80% FTC, and QBAI (10% routine return exclusion). Use the gilti etr result to inform your calculation.

GILTI Effective Tax Rate Calculation

Statute of Limitations

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