Join Baker Tilly’s experienced tax professionals for part three of this webinar series exploring the sweeping changes introduced by the One Big Beautiful Bill Act (OBBBA) (P.L. 119-21), signed into law on July 4, 2025. This series will provide timely insights into the most impactful provisions of the new tax law, including implications for businesses, individuals, international operations and those affected by changes to the Inflation Reduction Act (IRA). Each session will feature thoughtful commentary, key takeaways and practical planning considerations.
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.
Speakers: Dan Birsan, Wakako Byer, Roy Deaver, Nikki Grams, Jessica Jeane
Learning objectives
Upon completion of this course, attendees will be able to:
- 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
Who should attend
Business owners, CFOs, tax directors, vice presidents of tax, tax professionals and other financial executives
Information about CPE eligibility
There are no prerequisites for this webinar, and advance preparation is not required. There is no cost to attend this webinar.
A certificate of completion will be emailed to you four to six weeks after the event.
Level: Basic
CPE credit: One (1) hour total credit
Field of study: Taxes
For more information regarding administrative policies such as complaint and refund policies, please email learning@bakertilly.com.
Baker Tilly Advisory Group, LP 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 credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: nasbaregistry.org.
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The information provided here is of a general nature and is not intended to address the specific circumstances of any individual or entity. In specific circumstances, the services of a professional should be sought. Tax information, if any, contained in this communication was not intended or written to be used by any person for the purpose of avoiding penalties, nor should such information be construed as an opinion upon which any person may rely. The intended recipients of this communication and any attachments are not subject to any limitation on the disclosure of the tax treatment or tax structure of any transaction or matter that is the subject of this communication and any attachments.