NCTI: Because ‘GILTI’ Was Too Honest
The One Big Beautiful Bill Act (OBBBA) did not just modify GILTI—it effectively replaced it with a new framework: net CFC tested income (NCTI). While the name change may suggest a simple rebranding, the underlying rules have been materially revised, with significant implications for U.S. shareholders of controlled foreign corporations.
This program focuses on what actually changed—and what did not. Participants will walk through the transition from GILTI to NCTI, including revisions to the calculation of tested income, the removal of certain exclusions, and changes to the Section 250 deduction that increase the effective tax rate. The program will also address how these changes impact foreign tax credit calculations and overall tax liability.
Equally important, the program will highlight areas where the framework remains familiar, helping practitioners avoid overcorrecting or misapplying prior GILTI concepts. Emphasis is placed on practical application and practitioner decision-making, including how to evaluate the impact on existing structures, identify planning considerations, and communicate changes to clients.This program is designed for practitioners who already understand the basics of GILTI and need a clear, practical roadmap for navigating the new NCTI regime.Learning Objectives (NASBA)
Upon completion of this program, participants will be able to:
-Identify key changes introduced by OBBBA in transitioning from GILTI to net CFC tested income (NCTI).
-Determine how revisions to the calculation of tested income and the Section 250 deduction affect taxable income and effective tax rates.
-Analyze the impact of the NCTI regime on foreign tax credit calculations and U.S. shareholder reporting.
-Evaluate differences and similarities between the prior GILTI framework and the new NCTI rules.
-Assess planning considerations and practitioner responses to changes in the taxation of CFC income under OBBBA.
Only available for TPP unlimited CE subscribers.
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*Self-Study recording not available for NASBA CPE credit.
IRS Program #: 7Q3WU-T-00890-26
CTEC Course #: 6248-CE-00236
Rita Ryan
,
Esq., LLM
Rita Ryan is the Founder of RRITS and a seasoned Tax Attorney with more than 18 years of experience advising clients on cross-border personal/business taxation, international investment structuring, multi-jurisdictional estate planning, and U.S. tax compliance obligations arising from global activities and holdings. She is widely regarded for her ability to navigate complex international tax regimes and translate evolving regulatory requirements into practical, strategic guidance.
In addition to her client-facing work, Rita serves as a trusted advisor to fellow tax professionals, providing specialized support in identifying international reporting obligations, advising on complex filings, and reviewing workpapers and forms to ensure technical accuracy in an increasingly dynamic international compliance environment.
Prior to founding RRITS, Rita served as Chief Financial Officer and Head of Private Client Services at M+, where she focused on integrated tax, business, and wealth preservation planning for high-net-worth business owners and their families. Earlier in her career, she founded and led Wolf & Co.’s International Tax Services Practice, advising both individuals and entities on the tax planning and compliance aspects of international ownership structures. Rita began her legal career in private practice as an Associate Attorney at Vacovec, Mayotte & Singer, LLP, concentrating on international and domestic taxation, estate planning, and tax controversy matters.
Rita is also an Adjunct Professor in the Graduate Tax Program at Boston University School of Law, where she co-founded and co-teaches the course Foreign Information Reporting and Withholding. In addition, she regularly teaches advanced international tax topics for Tax Practice Pros, LumiQ, and the National Association of Enrolled Agents, contributing to the education of practitioners nationwide.
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