Glossary entry · code section
GILTI
Global Intangible Low-Taxed Income — the pre-OBBBA name for the §951A regime that taxes US shareholders on a CFC's tested income. Renamed NCTI by OBBBA §70323 effective TY2026.
Canonical reference
GILTI was renamed NCTI by OBBBA §70323 effective for tax years beginning after Dec 31, 2025. The underlying statute is §951A. See the full OBBBA reference for the rate, QBAI, and FTC changes.
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