Introduction
The Tax Cuts and Jobs Act (TCJA) of 2017 completely overhauled the U.S. international tax regime with the addition of several new provisions, most notably Global Intangible Low Taxed Income or GILTI. The so-called “One Big Beautiful Bill” (OBBB)[i] was signed into law in July 2025 includes several modifications in the international tax area. While the 2025 changes are not nearly as comprehensive and far-reaching as the 2017 changes, they could nevertheless have significant effects and outcomes.
Introduction The Tax Cuts and Jobs Act (TCJA) of 2017 completely overhauled the U.S. international tax regime with the addition of several new provisions, most notably Global Intangible Low Taxed Income or GILTI. The so-called “One Big Beautiful Bill” (OBBB)[i] was signed into law in July 2025 includes several modifications in the international tax area….
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