GILTI and FDII Calculations

Summary

This practice note reviews the fundamentals of the global intangible low-tax income (GILTI) and the foreign-derived intangible income (FDII) tax regimes. GILTI and FDII were both created by the Tax Cuts and Jobs Act of 2017 (TCJA). Pub. L. No. 115-97. After reviewing the fundamentals of the GILTI and FDII tax systems, this practice note provides an analysis of how to calculate GILTI. The practice note also outlines the FDII calculation.