IRS Publication 6075 – IRS Publication 6075, titled Global Intangible Low-Taxed Income, is an official IRS document from the Statistics of Income (SOI) Division. It provides statistical data and insights on Global Intangible Low-Taxed Income (GILTI) for tax year 2021. The latest revision is from March 2025 (Rev. 3–2025), available for download as a PDF directly from the IRS website: https://www.irs.gov/pub/irs-pdf/p6075.pdf.
This publication does not serve as comprehensive guidance on GILTI rules or calculations (those are covered in IRC Section 951A, regulations, and forms like Form 8992). Instead, it analyzes aggregate data from corporate tax returns to highlight trends, amounts reported, and breakdowns by industry and asset size.
What Is GILTI?
GILTI, introduced by the Tax Cuts and Jobs Act (TCJA) of 2017 under Section 951A, targets certain foreign income of Controlled Foreign Corporations (CFCs) owned by U.S. shareholders. It prevents base erosion by taxing U.S. shareholders on their pro rata share of a CFC’s “tested income” (generally active income exceeding a deemed return on tangible assets) that might otherwise escape U.S. taxation due to low foreign tax rates.
Key elements include:
- Tested income/loss — CFC income used to compute inclusions.
- Qualified Business Asset Investment (QBAI) — Basis in depreciable tangible property, allowing a 10% deemed return exclusion (net DTIR).
- GILTI inclusion = Net CFC tested income minus net DTIR.
- Domestic corporations generally qualify for a 50% Section 250 deduction on GILTI (effective rate ~10.5%), plus foreign tax credits (limited to 80% of deemed paid taxes).
GILTI applies to U.S. shareholders of CFCs and is reported using Form 8992 (U.S. Shareholder Calculation of Global Intangible Low-Taxed Income).
Key Statistics from IRS Publication 6075 (Tax Year 2021)
The publication analyzes data from corporation income tax returns (with Form 8992) for accounting periods ending July 2021–June 2022.
- Total GILTI reported: $607 billion.
- Tested income from parent corporations: $725 billion.
- Tested losses: $111 billion.
- Large corporations dominated: Parents with over $2.5 billion in assets represented 9.5% of returns but 96% of assets, 94% of GILTI, and $589 billion in net tested income.
- Smaller asset classes (e.g., $1M–$5M) showed net tested losses (e.g., $1.5 billion).
- Industry highlights:
- Manufacturing led with over 57% of total GILTI ($351 billion).
- Arts, Entertainment, and Recreation reported significant net CFC tested losses (over $236 million).
These figures illustrate GILTI’s concentration among large multinational corporations, particularly in high-profit sectors like manufacturing.
Who Needs to Understand IRS Publication 6075?
- Tax professionals and multinational corporations analyzing GILTI trends.
- Researchers or policymakers studying international tax compliance and profit shifting.
- U.S. shareholders of CFCs reviewing aggregate IRS data for context on reporting.
Note: GILTI rules evolved post-2021. For tax years beginning after December 31, 2025, significant changes occurred under legislation like the One Big Beautiful Bill Act (OBBBA), renaming it to Net CFC Tested Income (NCTI), adjusting deductions (e.g., Section 250 to 40%), increasing foreign tax credit availability (to 90%), removing the QBAI exclusion in some contexts, and shifting effective rates (e.g., ~12.6% for corporations). Publication 6075 focuses on 2021 data and does not cover these later reforms.
For official rules, refer to IRS resources like:
- Form 8992 and instructions.
- IRC Section 951A.
- Related publications (e.g., Publication 6076 on Section 250 deductions).
Download the full PDF for charts, detailed tables, and complete statistics: IRS Publication 6075.
This article draws from the official IRS document and cross-referenced IRS sources for accuracy as of the latest available information. Always consult a tax advisor for personalized application of GILTI/NCTI rules.