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GILTI / NCTI calculator
US tax on your share of a UK company's profits from 2026: no election, section 962 or the high-tax exclusion.
About this calculator
What it estimates
If you are a US citizen who owns a UK company, the US can tax your share of its profits each year, even if nothing is paid out. From 2026 this regime is called net CFC tested income. This calculator compares three outcomes for one company.
How it works
With no election, your share of the profit after UK tax is taxed at your personal rate, with no credit for UK corporation tax.
With a section 962 election, you are taxed as if you were a US corporation: a 40% deduction, a 21% rate and credit for 90% of the UK tax.
With the high-tax exclusion, income taxed abroad above 18.9% is left out altogether.
Assumptions (US 2026 tax year rates)
- •One controlled foreign corporation and no tested losses
- •Figures already in US dollars
- •No state tax or net investment income tax
Estimates only, for orientation. Rates and thresholds change each tax year and your actual liability depends on facts this tool does not ask for. This is not tax advice.
For US–UK filers
Why your real number differs
UK companies paying the 25% main rate usually qualify for the high-tax exclusion, so the real question is often whether the company is a CFC at all and how Form 5471 is completed. Dividends later paid after a 962 election are taxed again, to the extent they exceed the tax already paid. The UK-US treaty usually gives qualified dividend rates on those dividends.
Related
Sources
- IRC sections 951A, 250, 960 and 962, as amended by the One Big Beautiful Bill Act 2025
- Treas. Reg. 1.951A-2(c)(7) (high-tax exclusion)
- IRS Instructions for Form 8992 and Form 5471