Baker Tilly: Tax Reform 2025: Key International Tax Provisions

This session will cover the international tax changes introduced by the OBBBA, including updates to GILTI, FDII (now FDDEI), BEAT and other cross-border provisions.

Learning objectives:

- Summarize the transformation of GILTI into Net CFC Tested Income (NCTI), including changes to the GILTI deduction, the GILTI foreign tax credit as well as the application of changes to section 163(j) interest expense limitation in the GILTI context

- Discuss the rebrand and revamp of FDII to FDDEI, including the removal of the QBAI hurdle and its impact on export-focused businesses

- Review the limited updates to BEAT, including the revised BEAT rates and unchanging treatment of certain credits

- Evaluate the reinstatement of section 958(b)(4) and its implications for CFC ownership and deemed income inclusions

- Describe the permanent extension of the CFC look-through rule, the elimination of the one-month deferral exception and modifications to the deemed income inclusion pro rata share rules

- Consider the new sourcing rule that provides a fix for earlier modifications under section 863(b) available to certain US manufacturers

Speakers: Dan Birsan, Wakako Byer, Roy Deaver, Nikki Grams, Jessica Jeane

CPE credit: 1 credit

Field of study: Tax 

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Fee:

Complimentary