NCTI: Because ‘GILTI’ Was Too Honest

The One Big Beautiful Bill Act (OBBBA) did not just modify GILTI—it effectively replaced it with a new framework: net CFC tested income (NCTI). While the name change may suggest a simple rebranding, the underlying rules have been materially revised, with significant implications for U.S. shareholders of controlled foreign corporations.

This program focuses on what actually changed—and what did not. Participants will walk through the transition from GILTI to NCTI, including revisions to the calculation of tested income, the removal of certain exclusions, and changes to the Section 250 deduction that increase the effective tax rate. The program will also address how these changes impact foreign tax credit calculations and overall tax liability.

Equally important, the program will highlight areas where the framework remains familiar, helping practitioners avoid overcorrecting or misapplying prior GILTI concepts. Emphasis is placed on practical application and practitioner decision-making, including how to evaluate the impact on existing structures, identify planning considerations, and communicate changes to clients.

This program is designed for practitioners who already understand the basics of GILTI and need a clear, practical roadmap for navigating the new NCTI regime.

Learning Objectives (NASBA)
Upon completion of this program, participants will be able to:
-Identify key changes introduced by OBBBA in transitioning from GILTI to net CFC tested income (NCTI).
-Determine how revisions to the calculation of tested income and the Section 250 deduction affect taxable income and effective tax rates.
-Analyze the impact of the NCTI regime on foreign tax credit calculations and U.S. shareholder reporting.
-Evaluate differences and similarities between the prior GILTI framework and the new NCTI rules.
-Assess planning considerations and practitioner responses to changes in the taxation of CFC income under OBBBA.

2 IRS CE/2 NASBA CPE*

Only available for TPP unlimited CE subscribers.

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*Self-Study recording not available for NASBA CPE credit.

IRS Program #: 7Q3WU-T-00890-26
CTEC Course #: 6248-CE-00236