The One Big Beautiful Bill Act (P.L. 119-21) included several important revisions to international tax rules. For the most part, these changes tweaked the law to address concerns about how provisions in the Tax Cuts and Jobs Act operated, or to fix inconsistencies between them and pre-2017 law. The OBBBA also included substantive changes to the TCJA’s keystone provisions — global intangible low-taxed income is now net controlled foreign corporation tested income (NCTI), and foreign-derived intangible income is now foreign-derived deduction-eligible income….

The first in a series, this article considers additional changes to the international tax rules that could rationalize pre-2017 law with the TCJA, and suggests modifications needed to clean up the deadwood of a pre-GILTI system….