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Introduction

The Tax Cuts and Jobs Act (TCJA) moved the United States from a global tax system to a territorial one. § 951A of the TCJA—the global intangible low-taxed income (GILTI) inclusion—was created as one of the tools used by the government to prevent corporations from taking advantage of the new system by shifting profits to foreign subsidiaries in low-tax jurisdictions.

This primer discusses the purpose of the GILTI regime, when and to whom it applies, and the general method for determining the amount of tax liability a taxpayer would incur as a result of GILTI, taking into consideration its accompanying tax credits and deductions.

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