GILTI (Global Intangible Low-Taxed Income) provisions refer to a set of U.S. tax rules that impose a minimum tax on foreign earnings of controlled foreign corporations (CFCs) owned by U.S. shareholders. These provisions were introduced as part of the Tax Cuts and Jobs Act (TCJA) to prevent base erosion and profit shifting, targeting multinational companies that might shift profits to low-tax jurisdictions. GILTI ensures that U.S. taxpayers pay a minimum level of tax on their foreign income, even if it is not repatriated.
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