For tax years beginning after 31 December 2017, the Tax Cuts and Jobs 2017 Act introduces new provisions intended to prevent the erosion of the US tax base. This is achieved, in part, through US taxation of certain global intangible low-taxed income.

In short, global intangible low-taxed income inclusions will impact companies that have foreign earnings generated without a large aggregate foreign fixed asset base and whose earnings have been taxed at a low tax rate.