An AI model extracted this from the bill’s official record and can make mistakes. Check the official text ↗ (opens in new tab)

Global Intangible Low-Taxed Income (GILTI)

A U.S. tax imposed on certain income earned by controlled foreign corporations (foreign subsidiaries) of U.S. companies, intended to discourage companies from shifting profits to low-tax jurisdictions.

Round-Tripped Income

Income earned by a foreign subsidiary that is generated from selling goods or providing services back to customers in the United States, or for use within the United States.

Controlled Foreign Corporation (CFC)

A foreign company where more than 50% of its voting power or value is owned by U.S. shareholders, each owning at least 10% of the voting power.

Internal Revenue Code of 1986

The official compilation of all tax laws in the United States, enforced by the Internal Revenue Service (IRS).

Net Deemed Intangible Income Return

A specific calculation used in GILTI that represents a 10% return on a foreign subsidiary's tangible assets, which is then deducted from its tested income to arrive at the GILTI amount.

Round-Tripping Ratio

A percentage that compares a company's 'round-tripped income' to its total foreign income, used to adjust GILTI calculations and deductions under this bill.