Growing and Preserving Innovation in America Act of 2025

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.