Net CFC Tested Income
In more detail
Under the One Big Beautiful Bill Act, the GILTI regime is being relabelled as Net CFC Tested Income (NCTI) and revised for tax years beginning after 31 December 2025. The core idea — current US taxation of a controlled foreign corporation tested income — survives, but some of the calculation changes. Americans with UK companies should plan on current-year inclusion continuing under the new name.
Related terms
Does NCTI apply to your situation?
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