GILTI High-Tax Exclusion Gap Calculator

Check whether a foreign subsidiary clears the Global Intangible Low-Taxed Income (GILTI) high-tax exclusion. Provide the tested income and the foreign taxes booked, then optionally adjust the US corporate tax rate if legislation changes. The result shows percentage points above or below the exclusion threshold.

Total GILTI tested income in USD for the controlled foreign corporation.
Income taxes allocable to the tested income, expressed in USD.
Optional — defaults to 21% if blank so the threshold is 90% × 21% = 18.9%.

Educational modelling only — consult international tax advisors for compliance decisions.

Examples

  • Tested income $1,250,000, foreign taxes $240,000 ⇒ effective rate 19.20% vs 18.90% threshold, surplus +0.30 percentage points.
  • Tested income $900,000, foreign taxes $120,000 ⇒ effective rate 13.33% vs 18.90% threshold, shortfall −5.57 percentage points.

FAQ

What threshold does the calculator use?

By default the tool multiplies the US corporate tax rate by 90%, yielding the 18.9% trigger under current law. Adjust the rate input if Congress changes the statutory rate.

How should I treat foreign tax pools in multiple currencies?

Convert local currency taxes to USD using the average exchange rate for the taxable year so you compare like-for-like amounts with the tested income figure.

Does this account for qualified business asset investment (QBAI)?

No. QBAI reduces the GILTI inclusion amount but does not change the high-tax exclusion test, which is driven purely by the effective foreign tax rate.

Can I model Pillar Two top-up tax alongside GILTI?

Yes. Pair this result with the OECD Pillar Two Top-Up Tax calculator to see how divergent foreign effective rates impact both regimes.

Additional Information

  • A positive result means the foreign effective tax rate exceeds 90% of the US corporate rate, supporting the high-tax exclusion.
  • A negative gap indicates how many percentage points of foreign tax rate need to be added to qualify for the exclusion.
  • The calculator assumes foreign taxes are fully creditable and ignores expense allocation adjustments when comparing rates.
  • Use the output to benchmark carve-out entities against OECD Pillar Two top-up estimates or FTC modelling before year-end closes.

Related calculators