Partner Lowell D. Yoder authored this bylined article on the rules in section 951A for determining the amount of the GILTI Subpart F inclusion. The 2017 tax act added a new inclusion rule to Subpart F.2 A US shareholder of a controlled foreign corporation (CFC) must include in gross income the CFC’s global intangible low-taxed income (GILTI). This article discusses issues requiring guidance from the Treasury and IRS and suggests interpretations in the interim.