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2025 International Tax Legislation: One Big Beautiful Bill Act

New Terminology, Calculations, and Considerations: NCTI/GILTI, FDDEI/FDII, Downward Attribution Rules and FCFCs

Note: CLE credit is not offered on this program

A live 110-minute CPE webinar with interactive Q&A

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Tuesday, October 28, 2025

1:00pm-2:50pm EDT, 10:00am-11:50am PDT

Early Registration Discount Deadline, Friday, October 3, 2025

or call 1-800-926-7926
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This webinar will analyze foreign tax provisions contained in the One Big Beautiful Bill Act (OBBBA). Our panel of veteran international tax attorneys will explain the new provisions, their ramifications, and planning opportunities for global taxpayers.

Description

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.

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Outline

  1. The One Big Beautiful Tax Bill and international tax: introduction
  2. Controlled foreign corporations (CFCs)
  3. New Section 951B, Downward Attribution Rules
  4. Net CFC tested income (NCTI)
  5. Foreign-derived deductible eligible income (FDDEI)
  6. New Section 951B, Downward Attribution Rules
  7. New Section 904(b)(6), Inventory sourcing rules for FTC limitation
  8. BEAT
  9. Domestic provisions impacting and modified for foreign taxpayers
  10. Planning opportunities

Benefits

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

Faculty

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

Mr. Chesman has broad experience in federal, state, and international taxation, including consulting, compliance, and...  |  Read More

Fuller, Pamela
Pamela A. Fuller, Esq., J.D., LL.M.
Senior Counsel (Tax, M&A, International)
Tully Rinckey PLLC and Zahn Law Global

Ms. Fuller is a corporate and international tax attorney with over 20 years experience in advising a wide range of...  |  Read More

Attend on October 28

Early Discount (through 10/03/25)

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Early Discount (through 10/03/25)

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CPE On-Demand

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