• videocam Live Webinar with Live Q&A
  • calendar_month December 11, 2026 @ 1:00 PM ET/10:00 AM PT
  • signal_cellular_alt Intermediate
  • card_travel Tax Preparation - Foreign
  • schedule 110 minutes

OBBBA International Tax Reform: Implementing NCTI, FDDEI, and Section 951B

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Discount expires 11/27/26

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About the Course

Introduction

This CPE webinar will analyze the foreign tax provisions of the One Big Beautiful Bill Act (OBBBA), now in effect for tax years beginning after Dec. 31, 2025, and its practical implications for multinational businesses and their advisers. Our panel of veteran international tax practitioners will analyze the latest developments, implementation challenges, and planning opportunities arising from the transition to the new international tax framework.

Description

The OBBBA permanently reshaped the taxation of foreign earnings. Now that taxpayers are preparing returns under the post-OBBBA regime, attention has shifted from understanding the legislation to implementing it. Key international provisions are taking effect, requiring taxpayers to evaluate the impact of Net CFC Tested Income (NCTI), Foreign-Derived Deduction Eligible Income (FDDEI), revised foreign tax credit rules, and new compliance obligations for foreign-controlled structures.

The OBBBA also permanently extended several key international provisions and introduced new IRC Section 951B governing foreign-controlled foreign corporations (FCFCs). Taxpayers and advisers continue to analyze how restored Section 958(b)(4) rules, new FCFC provisions, and Section 951B interact with Subpart F inclusions, ownership structures, and reporting obligations. As additional guidance emerges, businesses must evaluate whether existing structures continue to achieve intended tax outcomes and whether new planning opportunities have become available.

Listen as our panel of respected international tax professionals discusses the implementation of the OBBBA's international tax provisions, reviews the current state of these international provisions and the guidance issued since enactment, and offers practical guidance for navigating the new cross-border tax landscape.

Presented By

Adam Chesman
Senior Director, Cross-Border Mergers and Acquisitions Tax Leader
RSM US, LLP

Mr. Chesman is a senior director and the tax leader of cross-border mergers and acquisitions in RSM US LLP’s international tax practice. A licensed attorney with broad experience in federal, state and international taxation, he joined RSM in 2017 as part of the firm’s Washington National Tax practice. Mr. Chesman provides consulting, compliance and audit assistance to clients, with a particular emphasis on structuring domestic and cross-border mergers and acquisitions. He works with a diverse array of clients, including high net worth individuals, corporations and partnerships across a variety of industries, primarily financial services, private equity and foreign-owned real estate. As part of the Washington National Tax practice, Mr. Chesman stays current with changing tax laws and provides updates to clients and field offices to ensure a position of tax efficiency.


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Pamela A. Fuller
Of Counsel (Tax, M&A, International)
Tully Rinckey PLLC and Zahn Law Global, LLP

Ms. Fuller is a corporate and international tax attorney with over 20 years experience in advising a wide range of clients -- including private clients and companies, joint ventures, private equity funds, HNW indviduals, C-Suite executives, "start-ups," and government entities -- on transactional, investment, and supply-chain strategies to achieve optimal tax and business results. She has deep expertise in structuring cross-border M&A transactions, and advising mobile international families. Her clients hail from a multitude of industries, including the burgeoning world of decentralized finance (DeFi). Pamela is also a seasoned taxpayer advocate, with decades of experience resolving complex U.S. federal, state, and foreign tax controversies. 

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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

    Friday, December 11, 2026

  • schedule

    1:00 PM ET/10:00 AM PT

I. The One Big Beautiful Tax Act, one year later

II. Controlled foreign corporations (CFCs)

III. Net CFC tested income (NCTI)

IV. Foreign-derived deductible eligible income (FDDEI)

V. Foreign tax credits 

VI. New Section 951B, Downward Attribution Rules

VII. New Section 904(b)(6), Inventory sourcing rules for FTC limitation

VIII. BEAT

IX. Planning opportunities



The panel will cover these and other critical issues:

  • Implementing NCTI and FDDEI for tax years beginning after Dec. 31, 2025
  • The impact of eliminating QBAI and modifying Section 250 deductions
  • Section 951B, FCFCs, restored Section 958(b)(4) rules, and ownership attribution considerations
  • Examples and illustrations incorporating the new rules and calculations

Learning Objectives

After completing this course, you will be able to:

  • Identify key international tax provisions enacted by the OBBBA that are effective beginning in 2026
  • Determine the impact of replacing GILTI and FDII with NCTI and FDDEI
  • 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.


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 .