GILTI ended deferral for most low-taxed CFC income. Size the inclusion before it becomes a provision surprise.
International
GILTI estimator that sizes your inclusion, deduction, and net tax cost.
Estimate GILTI inclusion, Section 250 deduction, and net US tax cost for CFC shareholders under the current TCJA framework.
Direct answerThis tool calculates the Global Intangible Low-Taxed Income (GILTI) inclusion by subtracting the deemed tangible income return from net CFC tested income, then applies the Section 250 deduction and foreign tax credit to estimate net US tax cost.
TCJA GILTISection 250Built for international tax
1. Enter CFC data and assumptions
EstimatorEnter CFC tested income, QBAI, foreign taxes, and rate assumptions. Or load the sample scenario.
Enter CFC assumptions or load a sample scenario to see the results.
Live Tool
GILTI Tax Exposure Estimator in the browser
The functional tool stays first: enter your CFC data and assumptions, review the result, and only then scroll into the guide below.
Privacy-first workflow
This page runs in the browser and does not upload any data.
What this tool is built to solve
A GILTI estimator calculates the inclusion by subtracting the deemed tangible income return from net CFC tested income, then applies the Section 250 deduction and FTC offset.
See the deduction amount and how it interacts with the FTC to reduce net US tax cost.
Compare the blended GILTI effective rate against the statutory rate to identify planning opportunities.
Key signals
The result cards explain where the GILTI tax cost is coming from.
Decision support
Use these cards to move from the estimate into the next international tax planning discussion.
Detailed breakdown
The breakdown keeps the math explainable and export-ready.
Calculate the net CFC tested income minus the deemed tangible income return to size the GILTI inclusion amount.
Apply the 50% (or 37.5% post-2025) deduction to see how much of the inclusion is sheltered before tax.
Factor in deemed-paid foreign tax credits to reduce the net US tax cost on the GILTI inclusion.
Compare the blended GILTI effective rate against the statutory rate to identify planning opportunities.
Guide Below The Tool
How to use the GILTI tax exposure estimator well
This section is written for searchers, answer engines, and busy international tax teams: direct definitions, practical steps, and concrete follow-up guidance.
A GILTI estimator calculates the Global Intangible Low-Taxed Income inclusion by subtracting the deemed tangible income return from net CFC tested income, then applies the Section 250 deduction and foreign tax credit to estimate net US tax cost.
US shareholders of controlled foreign corporations, international tax teams, CPAs advising multinational clients, and corporate tax departments managing CFC structures under the TCJA framework.
CFC tested income and losses, qualified business asset investment (QBAI), specified interest expense, foreign taxes paid by CFCs, the US marginal tax rate, and the Section 250 deduction percentage.
Workflow
Four practical steps
Use the tool as a fast decision layer. The goal is to move from raw CFC data to a usable GILTI exposure number before you open a larger international tax model.
1
Enter CFC tested income and tested losses.Start with the aggregate tested income and tested losses across all controlled foreign corporations.
2
Add QBAI, interest expense, and foreign taxes.Enter the qualified business asset investment, specified interest expense, and foreign taxes paid by the CFCs.
3
Set the US tax rate and Section 250 deduction percentage.Confirm the corporate tax rate and whether the 50% or 37.5% Section 250 deduction applies for the tax year.
4
Review the GILTI inclusion, deduction, FTC offset, and net tax cost.Carry the result into the next provision, planning model, or international tax review discussion.
Review Checklist
What reviewers usually validate first
These are the areas teams usually discuss first once the GILTI estimate is visible.
Confirm that tested income and tested losses are properly separated by CFC and that loss CFCs do not generate deemed-paid credits.
Verify that QBAI reflects the adjusted basis of depreciable tangible property used in a trade or business, not total assets.
Check that only interest expense allocable to tested income CFCs is included in the deemed tangible income return calculation.
Confirm whether the 50% deduction (pre-2026) or 37.5% deduction (post-2025) applies for the relevant tax year.
Verify that deemed-paid credits are subject to the GILTI basket limitation and do not exceed 80% of foreign taxes paid.
Consider whether a high-tax exclusion election under Section 954(b)(4) could remove certain CFC income from the GILTI base entirely.
Why This Page Exists
Built to close the gap between CFC data and a usable GILTI exposure number
Most search results either define GILTI or sell a larger international tax platform. This page solves the immediate job first: use the tool, see the inclusion and net tax cost, and understand what it means before you move into a deeper planning workflow.
The functional tool stays on top so users can solve the immediate GILTI question before reading a guide.
The result cards explain what the output means instead of leaving users with a raw number.
Ledger Summit can build richer international tax tooling later, but this page delivers value now.
FAQ
GILTI tax exposure questions, answered directly
Written in short form so searchers can get a clear answer without digging through generic product copy.
GILTI (Global Intangible Low-Taxed Income) is the excess of a CFC shareholder's net tested income over a deemed tangible income return (10% of QBAI minus specified interest expense). The inclusion is then reduced by a Section 250 deduction and offset by deemed-paid foreign tax credits.
US shareholders of controlled foreign corporations (CFCs), international tax teams, CPAs advising multinational clients, and corporate tax departments managing CFC structures under the TCJA framework.
CFC tested income and losses, qualified business asset investment (QBAI), specified interest expense, foreign taxes paid by CFCs, the US marginal tax rate, and the Section 250 deduction percentage are the main drivers.
No. The page runs the estimator in your browser and does not require a file upload for the base workflow.
Yes. If you need a richer model, recurring workflow automation, or an internal production version, Ledger Summit can build it around your process.
Next Step
Need this connected to a broader workflow?
Use the free browser tool first. If you need a richer model, reporting automation, or an internal production version, Ledger Summit can build the next layer around your process.
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