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.