TAX2604. International Changes

The 2025 One Big Beautiful Bill Act (OBBBA) introduces substantial changes to U.S. international tax rules, most of which will first apply in the 2026 tax year. This session will provide an overview of the international tax provisions that practitioners need to understand now—including the transition from GILTI to Net CFC Tested Income (NCTI), updates to FDDEI, modifications to foreign tax credit rules, and structural changes such as the reinstatement of Section 958(b)(4) and the permanent look-through rule. The session will also highlight key regulatory developments. The session will further provide practical guidance to help taxpayers of all sizes prepare for the transition, including considerations for modeling, provision work, and future compliance.

Learning Objectives:

• Identify the major international tax reforms enacted in H.R. 1, P.L. 119-21, commonly referred to as OBBBA, including changes to GILTI/NCTI, FDDEI, and foreign tax credit rules.
• Recognize the implications and timing of structural updates such as the reinstatement of Section 958(b)(4) and the permanent look-through rule.
• Recall recent and anticipated regulatory developments and how they may affect 2025 and 2026 returns.
• Determine transition-year planning approaches to incorporate legislative and regulatory changes into future modeling, reporting, and cross-border tax strategies.