Income Tax Guidance on Global Intangible Low-Taxed Income GILTI For Corporations, Individuals, Trusts, and Estates

Issued: January 28, 2020

Generally, for tax years beginning after December 31, 2017, the federal Tax Cuts and Jobs Act¹ created a new category of foreign-sourced deemed income—global intangible low-taxed income (“GILTI”). GILTI is included in gross income² and, therefore, impacts the determination of federal taxable income (“FTI”) for corporations and adjusted gross income (“AGI”) for individuals, trusts and estates. This notice provides guidance on how GILTI and related provisions of the Tax Cuts and Jobs Act impact Michigan income tax reporting.

¹Public Law 115-97, enacted December 22, 2017.
²IRC 951A. The GILTI provisions are effective for foreign corporations in months beginning after December 31, 2017, and to tax years of U.S. shareholders in which or with which such foreign corporations’ tax years end.