Global Intangible Low-Taxed Income (GILTI) requires U.S. shareholders of controlled foreign corporations to include a portion of the CFC’s annual net tested income in their corporate taxable income, regardless of whether actual distributions occur. Specifically, the effective GILTI rate for corporate filers stands at approximately 10.5% — derived from applying the 50% §250 deduction to the 21% statutory rate — though the §250 deduction faces limitation when taxable income falls below the GILTI inclusion. Furthermore, the SBIE exempts income attributable to 10% of the CFC’s qualified business asset investment (QBAI) from the GILTI base. Consequently, U.S. multinationals must integrate GILTI projections — net of SBIE exclusions and available §960 foreign tax credits — into quarterly corporate income tax payable calculations to avoid underpayment penalty exposure throughout the year.