Growing and Preserving Innovation in America Act of 2025
This bill makes permanent the increased percentage rates at which a domestic corporation may deduct (for federal tax purposes) foreign-derived intangible income and global intangible low-taxed income (GILTI).
As background, for tax years beginning after 2017 and before 2026, a domestic corporation generally is allowed a tax deduction equal to the sum of (1) 37.5% of the corporation’s foreign-derived intangible income, and (2) 50% of the corporation’s GILTI and any dividends that are attributable to the corporation’s GILTI. However, under current law, the tax deduction decreases starting in 2026, to the sum of (1) 21.875% of the corporation’s foreign-derived intangible income, and (2) 37.5% of the corporation’s GILTI and any dividends that are attributable to the corporation’s GILTI.
Under the bill, for tax years beginning in 2026, a domestic corporation generally may claim a tax deduction equal to the sum of (1) 37.5% of the corporation’s foreign-derived intangible income, and (2) 50% of the corporation’s GILTI and any dividends that are attributable to the corporation’s GILTI.