The Evolution of GILTI Under the OBBBA: A Comprehensive Analysis of the New NCTI Regime
The One Big Beautiful Bill Act (OBBBA), enacted in July 2025, introduces the most consequential shift in U.S. international tax rules since the Tax Cuts and Jobs Act of 2017 (TCJA). Among its most significant changes is the replacement of the Global Intangible Low-Taxed Income (GILTI) regime with the new Net CFC Tested Income (NCTI) framework.
