The passage of the One Big Beautiful Bill Act (OBBBA) represents a defining moment in U.S. international taxation, one with lasting implications for multinational businesses. While celebrated for simplifying some aspects of the tax code, the act also reconfigures foundational provisions, prompting companies to reassess their global strategies.
In this episode of Grant Thornton’s D.C. Dispatch podcast, David Sites, National Managing Principal in the Washington National Tax Office, talked with Cory Perry, a Tax Services Principal about these new provisions. Together, they examined how the OBBBA reshapes key regimes, including the transformation of the Tax Cuts and Jobs Act’s FDII and GILTI into, respectively, FDDEI (foreign-derived deduction eligible income) and NCTI, (net CFC-tested income), and what those changes mean. The two also review the act’s impact on foreign tax credits, expense allocation, and the treatment of qualified business asset investment (QBAI).
Their discussion highlights both risks and opportunities. Manufacturers and asset-heavy businesses may face challenges with the elimination of QBAI, while highly leveraged or R&D-intensive companies could benefit from new rules that remove restrictive expense apportionments. At the same time, favorable changes to the foreign tax credit haircut promise relief for many taxpayers. Beyond these technical shifts, Sites and Perry emphasize the broader need for companies to reevaluate global structures, supply chains, and financing strategies in light of OBBA’s permanence and its interaction with parallel international developments like OECD Pillar 2.
To gain deeper insights into how OBBBA may affect your business, listen to the full discussion.
Contacts:
National Managing Partner,
Washington National Tax Office and International Tax Solutions
Grant Thornton Advisors LLC
David leads the firm's International Tax practice, which focuses on global tax planning, cross border merger and acquisition structuring, and working with global organizations in a variety of other international tax areas.
Washington DC, Washington DC
Industries
- Manufacturing, Transportation & Distribution
- Technology, Media & Telecommunications
- Retail & Consumer Brands
Service Experience
- Tax Services
- International Tax
Partner, International Tax
Washington National Tax Office
Grant Thornton Advisors LLC
Cory Perry is a partner in Grant Thornton’s Washington National Tax Office and has worked for more than 12 years in international tax.
Washington DC, Washington DC
Industries
- Manufacturing, Transportation & Distribution
- Technology, Media & Telecommunications
- Private Equity
Service Experience
- Tax Services
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