2025 International Tax Legislation: One Big Beautiful Bill Act

The OBBBA has significant implications for multinational taxpayers and their businesses. There is more to address than new and extended tax provisions. Also included are new rates and terminology. The familiar term GILTI has been revised and replaced with Net CFC Tested Income (NCTI), and FDII has been revised and renamed Foreign-Derived Deductible Eligible Income (FDDEI). 

Changes to GILTI, now NCTI, include the elimination of the QBAI (Qualified Business Asset Investment) exclusion and an increased FTC for CFC taxes by way of a change to the credit reduction rate. Previously, the FTC was reduced by 20%; now the credit is reduced by 10%, which allows an FTC of up to 90% compared to the former 80%.

The Act also decreases the Section 250 deduction for NCTI and FDDEI to 40% and 33.34%, respectively, from the previously applicable rates of 50% and 37.5%. Although BEAT retains its name, its tax rate has permanently increased from 10% in 2025 to 10.5%.

In addition to rate and name changes, the OBBBA also includes new and revised international tax provisions. The Section 954(c)(6) look-through rule for CFCs has been permanently extended. A new IRC Section 951B has been added to incorporate foreign-controlled CFCs (FCFCs) in the downward attribution rules. International tax advisers and multinational taxpayers need to reassess tax planning for multinational businesses in light of the OBBBA.

Listen as our panel of respected international tax professionals reviews the international provisions in the new tax bill.

I. The One Big Beautiful Tax Bill and international tax: introduction

II. Net CFC tested income (NCTI)

III. Foreign-derived deductible eligible income (FDDEI)

IV. BEAT

V. Controlled foreign corporations (CFCs)

VI. Domestic provisions impacting and modified for foreign taxpayers

VII. Planning opportunities

The panel will cover these and other critical issues:

• Modifications to prior GILTI/NCTI and FDII/FDDEI computations
• The permanent extension of the downward attribution rules and new Section 951 for foreign-controlled CFCs
• Domestic provisions impacting foreign taxpayers and businesses
• Examples and illustrations incorporating the new rules and calculations

Learning Objectives

After completing this course, you will be able to:

• Identify new terminology incorporated in the OBBBA
• Determine how to calculate NCTI, previously GILTI, under 2025 legislation
• Decide how the extension of the downward attribution rules and new provisions for FCFCs impact multinational taxpayers
• Ascertain planning opportunities provided by the OBBBA

• Field of Study: Taxes
• Level of Knowledge: Intermediate
• Advance Preparation: None
• Teaching Method: Seminar/Lecture
• Delivery Method: Group-Internet (via computer)
• Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
• Prerequisite:

  Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of international taxation including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI, Subpart F, and the related Section 250 deductions.

  
  

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