New Federal Tax Law Reshapes International Tax Landscape for U.S. Businesses

One Big Beautiful Bill Act brings major changes for U.S. taxpayers with international operations

Feb. 9, 2026 at 8:55pm

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The recently enacted One Big Beautiful Bill Act has significantly revised several international tax provisions originally introduced by the 2017 Tax Cuts and Jobs Act, affecting how multinational corporations and U.S. investors calculate foreign income, claim deductions, and determine controlled foreign corporation status.

Why it matters

These changes could increase exposure for asset-heavy foreign subsidiaries while reducing incentives to hold tangible assets offshore. Businesses with export-oriented operations or significant domestic production are encouraged to reassess eligibility and potential benefits under the new regime.

The details

Key changes include the replacement of the Global Intangible Low-Taxed Income (GILTI) framework with a new Net CFC Tested Income regime, the renaming of Foreign-Derived Intangible Income (FDII) to Foreign-Derived Deduction Eligible Income, the narrowing of Controlled Foreign Corporation (CFC) rules, and the expansion of pro rata share rules for Subpart F and foreign income inclusions.

  • The One Big Beautiful Bill Act was signed into law in July 2025.
  • Most of the new provisions will take effect beginning in 2026.

The players

SingerLewak

An accounting and advisory firm assisting clients with evaluating the impact of the new provisions and developing forward-looking strategies.

Daniel Sheinfeld

A member of SingerLewak's International Tax team.

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What they’re saying

“Although the new law simplifies certain calculations, advisers emphasize that it introduces new modeling, tracking, and restructuring considerations for multinational enterprises.”

— Daniel Sheinfeld, International Tax team member

What’s next

Taxpayers are advised to revisit ownership structures and filing requirements to identify opportunities for relief while evaluating potential exposure under the new regime.

The takeaway

The One Big Beautiful Bill Act brings significant changes to the international tax landscape for U.S. businesses, requiring careful evaluation and planning to navigate the new provisions and their potential impact on multinational operations.