BarbriSFCourseDetails
  • videocam Live Online with Live Q&A
  • calendar_month October 30, 2025 @ 1:00 p.m. ET./10:00 a.m. PT
  • signal_cellular_alt Intermediate
  • card_travel Tax Preparer
  • schedule 110 minutes

2025 International Tax Legislation: One Big Beautiful Bill Act

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

$197.00

This course is $0 with these passes:

CPE
ALL
  1. keyboard_arrow_leftBack
BarbriPdBannerMessage

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.

Presented By

Attorney Annie
Davis Brown Law Firm - Des Moines

Bio for Annie Attorney; loves horses and arguments

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio
Big Boat
The Mogy Law Firm - Memphis

This is a bio for Big Boat. Big Boat is an avid reader and unicyclist.

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio
Credit Information

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

Date + Time

  • event

    Thursday, October 30, 2025

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

I. The One Big Beautiful Tax Bill and international tax: introduction

II. Controlled foreign corporations (CFCs)

III. Net CFC tested income (NCTI)

IV. Foreign-derived deductible eligible income (FDDEI)

V. New Section 951B, Downward Attribution Rules

VI. New Section 904(b)(6), Inventory sourcing rules for FTC limitation

VII. BEAT

VIII. Domestic provisions impacting and modified for foreign taxpayers

IX. Planning opportunities

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

Learning Objectives

After completing this course, you will be able to:

  • Identify new terminology incorporated in the OBBBA
  • Determine how to calculate NCTI, previously GILTI, under 2025 legislation
  • Decide how the extension of the downward attribution rules and new provisions for FCFCs impact multinational taxpayers
  • Ascertain planning opportunities provided by the OBBBA
  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite:

    Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of international taxation including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI, Subpart F, and the related Section 250 deductions.


BARBRI, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

BARBRI CE webinars-powered by Barbri-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .