Section 951A category income refers to GILTI — Global Intangible Low‑Taxed Income.
This category was created by the Tax Cuts and Jobs Act (TCJA) and is one of the foreign income “baskets” that must be kept separate for the calculation of the Foreign Tax Credit.
What it includes
Under 26 U.S. Code § 951A, U.S. shareholders of controlled foreign corporations (CFCs) must include in their gross income their share of the CFC’s net tested income (after reducing for tested losses).
Plain‑language explanation
This is not income you earned directly.
Instead, it is a mandatory inclusion of certain types of foreign corporate income from CFCs to prevent companies from shifting profits to low‑tax countries.