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.
Understanding the Changes to the SALT Deduction Under the One Big Beautiful Bill Act (OBBBA)
The State and Local Tax (SALT) deduction has long been an important provision of the U.S. federal tax code. It allows taxpayers who itemize deductions to reduce their federal taxable income by the amount of certain state and local taxes paid, including income, sales, and property taxes. Historically, this deduction was intended to prevent double taxation—that is, taxing the same income at both the federal and state levels.
Section 1202 QSBS: Expanded Tax Benefits Under the OBBBA
The Qualified Small Business Stock (QSBS) exclusion, governed by Section 1202 of the tax code, has historically provided a crucial incentive for investment in eligible C-corp startups. This benefit allowed founders and early investors to exclude up to $10 million in capital gains, or 10× the investment basis, from federal taxation, provided the stock was held for a minimum of five years.
How the One, Big, Beautiful Bill Act Reshapes R&E Tax Treatment – Strategic Tax and Compliance Implications for Businesses
The One, Big, Beautiful Bill Act (OBBBA), signed into law on July 4, 2025, marks one of the most transformative tax developments for innovation-driven businesses in recent years. Among its many provisions, the Act fundamentally overhauls the tax treatment of Research and Experimental (R&E) expenditures, effectively reversing the restrictive capitalization rules introduced under the 2017 Tax Cuts and Jobs Act (TCJA).
Beneficial Ownership Information (BOI) Reporting
As of January 1, 2024, the bipartisan Corporate Transparency Act (CTA) requires many companies operating in the United States to report information about their beneficial owners—the individuals who ultimately own or control the company. This law aims to combat illicit finance and strengthen U.S. national security.
Tax Implications of Cross-Border Stock Transactions: Multinational Companies
Discover the intricate world of cross-border stock transactions and unravel the tax implications that multinational companies face.
Harnessing Tax Savings with IRC Section 1202: Qualified Small Business Stock (QSBS)
Taxes are an inevitable part of our financial lives, but savvy investors and entrepreneurs are always on the lookout for legal ways to reduce their tax liabilities.
Expanding Your Startup into the US Market: Key Considerations
Expanding a business into new markets is a thrilling venture, but it’s also a complex undertaking that requires careful planning and execution.
Investment in the USA: Choosing the Right Business Structure for Foreign Investors
Imagine a global entrepreneur with big dreams setting their sights on the United States, a land of endless possibilities.
Crafting a Compelling Investor Deck: The Key to Successful Capital Raising
In the competitive landscape of fundraising, securing additional capital is a crucial milestone for businesses of all sizes and industries.
