How the OBBBA Rewrites GILTI and FDII Tax Rules for U.S. Multinational Businesses
The One Big Beautiful Bill Act (OBBBA) introduces sweeping changes to U.S. international tax rules, redefining GILTI as Net CFC Tested Income (NCTI) and FDII as Foreign-Derived Deduction Eligible Income (FDDEI). These updates, effective in 2026, will significantly impact tax planning for multinational businesses.









