GILTI stands for global intangible low-taxed income. GILTI is intended to currently tax earnings in foreign corporations that were subject to a low tax rate rather than allow deferral of tax on that income. Despite the name, GILTI is not necessarily limited to taxing income from intangible assets. Essentially, the GILTI tax regime is a worldwide minimum tax on overseas earnings resulting in a current U.S. tax on U.S. shareholders of controlled foreign corporations (CFCs) to the extent those earnings exceed a 10 percent return on tangible assets of the CFC (plus certain interest expense.) For certain shareholders, a 50% deduction is available which results in a net effective corporate tax rate of 10.5% on GILTI income.