What is the GILTI high-tax exclusion, and how do I elect it?
My CFC is in a country with a 25% corporate tax rate. My tax advisor mentioned that there's a 'high-tax exclusion' for GILTI that could mean I don't have to include this income. How does it work? Is it automatic or do I need to make an election? And what's the threshold — what tax rate counts as 'high' enough to qualify?
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