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GILTI / NCTI calculator for US founders

Estimate the year-1 US tax on your foreign corporation's GILTI (tax year 2025) or NCTI (tax year 2026+) inclusion. Compares the three available paths: without §962, with §962 election, and the high-tax exclusion.

Tax year

The 2025 returns filed in 2026 use the original GILTI math. From tax year 2026 onward, OBBBA (Public Law 119-21) renames the regime to NCTI, drops §250 deduction from 50% to 40%, eliminates NDTIR carve-out, and raises the §962 FTC limit from 80% to 90%.

Year 2026+ estimate

NCTI regime
Tested income
$270,000
NCTI inclusion
$270,000
§250 rate
40%
§962 FTC limit
90%

Without §962 election

37% ordinary rate × inclusion. Individual cannot claim deemed-paid FTC.

Net US tax
$99,900
Effective rate
37.0%

With §962 election

Best

Treated as C-corp: 21% × (inclusion − 40% §250 deduction), less 90% of foreign tax as FTC.

Net US tax
$22,140
Effective rate
8.2%
Show calculation
§250 deduction$108,000
Taxable amount$162,000
Pre-credit US tax$34,020
§962 deemed-paid FTC−$11,880

High-tax exclusion (HTE)

Excludes inclusion entirely if CFC's foreign effective rate ≥ 18.9%. Your CFC: 4.9%.

✗ Not eligible (foreign rate too low)

Net US tax
$22,140
Effective rate
8.2%

Estimator only, not tax advice. v1 models year-1 only. It does NOT model PTEP recapture at distribution, state-level taxes (CA / NY conform to GILTI inclusion), Section 904 basket limitations across categories, or Subpart F overlap. For US international tax structures get a CPA who handles foreign corporations.

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