The U.S. Congressional Research Services (CRS) has published an "in focus" report dated 13 October 2021 on GILTI: Proposed Changes in the Taxation of Global Intangible Low-Taxed Income, providing an overview of the current rules and changes in the reconciliation bill (H.R. 5376), the "Build Back Better Act". --- GILTI: Proposed Changes in the Taxation of Global Intangible Low-Taxed Income The treatment of income earned abroad in U.S.-controlled foreign corporations (CFCs) has been extensively debated over the years. In the 2017 Tax Cuts and Jobs Act (P.L. 115-97), the tax treatment of foreign source income was altered. The prior system...