global intangible low-taxed income

(1) In general The term “global intangible low-taxed income” means, with respect to any United States shareholder for any taxable year of such United States shareholder, the excess (if any) of— (A) such shareholder’s net CFC tested income for such taxable year, over (B) such shareholder’s net deemed tangible income return for such taxable year.

Source

26 USC § 951A(b)(1)


Scoping language

For purposes of this section
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