While the full amount of gilti is includible in the us shareholder’s income, the net gilti inclusion is reduced through a 50% deduction in tax years beginning after december 31, 2017, and before january 1, 2026 (and a 37.5% deduction in tax years beginning after december 31,. Shareholders in which or with which those tax years of foreign corporations end. Global Intangible Low-tax Income - Working Example Executive Summary - Mksh To be eligible for the exclusion, the cfc’s earnings must be subject to an effective foreign corporate income tax rate that is greater than 90% of the current u.s. Gilti high tax exception pwc . While the full amount of gilti is includible in the us shareholder’s income, the net gilti inclusion is reduced through a 50% deduction in tax years beginning after december 31, 2017, and before january 1, 2026 (and a 37.5% section 163(j) business interest expense limitation. High tax exception gilti pwc. 954(b)(4) was significantly affected by the law known as the...