  		  The United States has two sets of CFC inclusion rules.  A U.S. shareholder must include in income their share of the subpart F income (generally, passive/mobile income) of a CFC.  The subpart F income rules include a   de minimis rule   - income that would otherwise be subpart F income is not treated as subpart F income if it is less than the lesser of 5% of the CFC’s gross income or USD $1,000,000.  However, all of a CFC’s income will be treated as subpart F income if the CFC’s subpart F income and insurance income exceeds 70% of the CFC’s gross income.  The subpart F income rules also include a high tax exception – subpart F income that is subject to an effective rate of income tax imposed by a foreign country greater than 90% of the maximum rate of U.S. tax imposed on corporations (currently, greater than 18.9%).  The second set of rules (adopted in 2017) requires a U.S. shareholder to include in income their global intangible low-taxed income (GILTI).  The GILTI rules apply a formulaic approach which generally requires an income inclusion by the U.S. shareholder based on their share of the income of their CFCs after excluding a 10% return on tangible assets of the CFCs from the GILTI amount.  Such income also excludes income that is effectively connected to a trade or business in the United States (which is taxed separately), subpart F income, related-party dividends, foreign oil and gas extraction income, or income that would be subpart F but is excluded by the high-tax exception.  In addition, the GILTI regime has an exclusion for high-taxed income, pursuant to an election, similar to the high tax exception for the Subpart F rules.  
  