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It also explained the taxation of foreign entities, Controlled Foreign Corporation (CFC) rules, and how certain foreign earnings are taxed to U.S. shareholders.
VV
The OBBBA replaced the Global Intangible Low-Taxed Income (GILTI) regime with Net Controlled Foreign Corporation Tested Income (NCTI), simplifying the calculation while continuing to tax certain foreign earnings of Controlled Foreign Corporations (CFCs)
Patrick McCormick Doc. of Law
The gunnercooke LLP
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