BarbriSFCourseDetails
  • videocam Live Webinar with Live Q&A
  • calendar_month April 27, 2026 @ 1:00 p.m. ET./10:00 a.m. PT
  • signal_cellular_alt Intermediate
  • card_travel Tax Preparer
  • schedule 110 minutes

Net CFC Tested Income: Planning for Inbound Real Estate Investment

NCTI vs. GILTI, Section 250 Deductions, Attribution Rules, Foreign Tax Credits, Typical Structures

Early Bird Pricing!
MSRP
$197.00
$167.45
Save $29.55

Discount expires 4/13/26

This course is $0 with these passes:

CPE
ALL
  1. keyboard_arrow_leftBack
BarbriPdBannerMessage

About the Course

Introduction

This webinar will review the components of net CFC tested income (NCTI) and offer planning strategies incorporating these new rules. Our panel of knowledgeable international tax advisers will explain typical CFC structures and provide applicable case studies.

Description

NCTI is the new regime introduced by the One Big Beautiful Bill Act, replacing GILTI (global intangible low-taxed income) for tax years beginning in 2026. A shareholder's ownership of 10% or more of a CFC triggers NCTI. In addition to the new name, the GILTI tax rate will rise from 10.5% to 12.6% under NCTI. The deduction for qualified business asset investment (QBAI) has also been eliminated. 

Strategies exist for U.S. owners of foreign entities to mitigate the tax impact of NCTI. Choosing the appropriate entity structure is a critical determination. Investors and tax advisers may want to consider a simple or leveraged corporate blocker, a domestically controlled REIT, or a direct investment through a trust. Understanding the new NCTI calculations and planning for inbound real investment is key to lowering a real estate investor's tax burden. 

Listen as our panel of seasoned tax professionals compares and contrasts GILTI and NCTI and offers strategies to mitigate tax liability for U.S. shareholders of CFCs. 

Presented By

Bradley Mainguy
Director
Baker Tilly

Mr. Mainguy has more than eight years of public accounting experience providing international tax services to clients in a wide range of industries, as well as individuals and publicly traded companies. He has extensive experience working with multinational corporate clients on consulting and compliance projects, including global business model optimization and restructuring projects from the design and feasibility stage through implementation. Mr. Mainguy also has expertise in U.S. tax issues relating to both inbound and outbound investments, as well as navigating the increasingly complex network of reporting, disclosure, and withholding requirements arising from doing business in a global economy.

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio
Amanda D. Scott, JD, LL.M.
Tax Manager
Baker Tilly

Ms. Scott, JD, LL.M., is a Tax Manager in the International Tax practice at Berkowitz Baker Tilly. She works with multinational businesses, investment structures, and high net worth individuals on the U.S. tax issues that arise when money, entities, and ownership cross borders. Ms. Scott work focuses on foreign corporations and offshore investments, including the Subpart F, GILTI, and PFIC regimes, as well as foreign trust considerations. She also helps clients navigate their international reporting obligations and the complexities that come with operating globally. Ms. Scott holds an LL.M. in Taxation from NYU and a Juris Doctor from the University of South Carolina.

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio
Credit Information

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

Date + Time

  • event

    Monday, April 27, 2026

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

I. NCTI

A. CFCs

1. Ownership tests

2. Attribution rules

3. Elimination of downward attribution

B. Net tested income

1. Compared to GILTI

2. Elimination of QBAI

3. Section 250 deduction

4. Foreign tax credits

C. Planning challenges and opportunities

1. Resource-intensive industries

2. Case studies

II. Planning for inbound real estate investment

A. U.S. taxation

1. FDAP withholding

2. ECI

3. FIRPTA

4. Estate and gift tax

B. Typical structures

1. Simple U.S. corporate blocker

2. Leveraged corporate blocker

3. Domestically-controlled REITS

4. Direct investment via trusts

C. Planning challenges and case studies

The panel will cover these and other critical issues:

  • Comparing GILTI and NCTI reporting rules
  • Planning strategies for inbound real estate investors
  • Choosing an appropriate structure for CFCs
  • Case studies applying new NCTI guidelines


Learning Objectives

After completing this course, you will be able to:

  • Determine how NCTI rules differ from GILTI
  • Identify appropriate structures for CFCs
  • Ascertain planning strategies for inbound real estate investment
  • Decide how the elimination of QBAI impacts taxable income
  • 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/NCTI, Subpart F, and the related Section 250 deductions.

BARBRI, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

BARBRI CE webinars-powered by Barbri-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .