I'm a US citizen with a Canadian corporation. Is GILTI still called GILTI?

No. Public Law 119-21, enacted 4 July 2025, renamed it. The statute now calls it net CFC tested income, and the change is more than cosmetic: the same Act struck out the qualified business asset investment rules and the net deemed tangible income return, and cut the section 250 deduction from 50 percent to 40. If you own a Canadian corporation and your planning predates that, it’s describing a regime that no longer exists in those terms.

What exactly did the 2025 Act change?

It rewrote the vocabulary and removed a whole mechanic. The amendment notes to the Code record it directly: the section catchline of IRC 951A was changed, and the subsection that defined the old concepts was struck out rather than amended. That distinction matters, because a struck-out definition doesn’t survive anywhere.

“2025, Pub. L. 119-21, s. 70323(a)(3)(E)(i), substituted ‘Net CFC tested income’ for ‘Global intangible low-taxed income’ in section catchline.” IRC 951A, amendment notes

The removal is recorded in the same place and is the substantive half. Section 70323(a)(2) “redesignated subsec. (c) as (b) and struck out former subsec. (b) defining ‘global intangible low-taxed income’ and ‘net deemed tangible income return’”, and separately “redesignated subsec. (f) as (d) and struck out former subsec. (d) which related to qualified business asset investment”. So the routine return on tangible assets, the piece that used to shelter a slice of income before any inclusion, is gone from the section entirely.

Did the deduction percentage change too?

Yes, from 50 percent to 40. The current text of section 250 sets the deduction at 40 percent of the net CFC tested income amount included under section 951A, and the amendment note records the substitution explicitly. A related figure moved at the same time: the foreign-derived percentage went from 37.5 to 33.34.

“Pub. L. 119-21, s. 70321(a)(2), substituted ‘40 percent’ for ‘50 percent’ in introductory provisions.” IRC 250, amendment notes

What it was called before July 2025	What the statute says now
Global intangible low-taxed income (GILTI)	Net CFC tested income
Qualified business asset investment (QBAI)	Struck out of section 951A
Net deemed tangible income return	Struck out of section 951A
Section 250 deduction of 50 percent	40 percent
Foreign-derived intangible income, 37.5 percent	Foreign-derived deduction eligible income, 33.34 percent

Do I get that 40 percent deduction as an individual?

Not directly, and this is the part that catches individual owners. Section 250 opens by granting the deduction to a domestic corporation. An individual US shareholder isn’t a domestic corporation, so the deduction isn’t simply available on a personal return the way it is to a company.

“In the case of a domestic corporation for any taxable year, there shall be allowed as a deduction an amount equal to the sum of … 40 percent of … the net CFC tested income amount (if any) which is included in the gross income of such domestic corporation under section 951A” IRC 250(a)(1)

That gap is why the section 962 election exists in these conversations. It lets an individual US shareholder elect to be taxed on certain inclusions at corporate rates instead of individual ones. Whether it gives you a better answer on your facts is a computation rather than a rule, and the interaction between that election and the section 250 deduction is governed by regulation rather than by the plain text quoted here, so it’s worth pricing rather than assuming.

What is the section 962 election, in plain terms?

An election by an individual to have certain controlled-foreign-corporation inclusions taxed as though a domestic corporation had received them. The statute frames it as substituting the corporate tax computation for the ordinary individual one on those specific amounts.

“a United States shareholder who is an individual and who elects to have the provisions of this section apply for the taxable year, (1) the tax imposed under this chapter on amounts which are included in his gross income under section 951(a) shall (in lieu of the tax determined under sections 1 and 55) be an amount equal to the tax which would be imposed under section 11 if such amounts were received by a domestic corporation” IRC 962(a)

• Whether you have a Form 5471 obligation on the corporation
• What happens to a Canadian corporation when you move to the US
• Whether to wind up the corporation or keep it

Two limits on this page, stated rather than glossed over. It doesn’t compute whether an election helps you, because that depends on your rates, your Canadian corporate tax and the credit mechanics. And it doesn’t cover the foreign tax credit rules that sit alongside these provisions, which were also touched by the same Act and are their own analysis.

What should I do next?

Check the date on whatever analysis you’re working from, because anything predating July 2025 is describing superseded text on all three points. Then get the current-year computation run properly rather than adjusting an old one, since removing the tangible-asset return changes the base rather than just the rate.

This guide is general information, not tax advice for your specific situation. Which points apply, and how, depends on your facts.