Question: is gilti subject to niit?
Answer: Based on your ownership level in the CFC, your portion of the GILTI will be subject to tax. For the 2018 tax year, there is a deduction of 50% of the GILTI available, but only for US corporate taxpayers. The taxable GILTI is then taxed at the ordinary tax rates of up to 37% plus possibly NIIT of 3.8%.