Introduced in 2017 as part of the Tax Cuts and Jobs Act, GILTI, or “Global Intangible Low Tax Income,” is an outbound provision that broadens the scope of foreign earnings subject to U.S. taxation with the goal of reducing the incentive to shift corporate profits out of the U.S. into low or zero-tax jurisdictions.[1] Applicable to large multinational companies and to U.S. shareholders of certain foreign corporations, GILTI is fundamentally an anti-deferral provision that limits the amount of foreign income a U.S. shareholder can defer from U.S. tax.