Everything You Need to Know About CFCs Post the One Big Beautiful Bill

The OBBBA has fundamentally reshaped international tax. Join our new partner, Ayelet Duskis, for an essential deep dive into the 2026 CFC landscape covering the shift from GILTI to NCTI, new expense allocation rules, and downward attribution. 

Learning Objectives: Participants will learn how to determine CFC status under the post‑OBBA rules, identify U.S. shareholders, and apply the updated Subpart F, GILTI, and §956 inclusion mechanics. They will understand key structural and planning implications of the new attribution framework, recognize updated Form 5471 reporting considerations, and work through practical examples to confidently analyze foreign structures in the current regulatory environment.

Learning Outcomes: Participants will be able to:

• Identify when a foreign corporation is classified as a CFC under the post‑OBBA rules, including how the revised attribution framework affects ownership testing.
• Determine U.S. shareholder status using the updated definitions and analyze how OBBA changed prior‑law outcomes for individuals, families, funds, and corporate groups. Apply Subpart F, GILTI, and §956 rules to CFCs under the new regime and understand how OBBA alters income inclusion modeling.
• Evaluate cross‑border structures for risk and opportunity in light of OBBA-driven changes to indirect ownership, multi‑tier entities, and investment vehicles.
• Interpret updated compliance requirements, including Form 5471 reporting considerations, attribution disclosures, and common areas of IRS scrutiny.
• Analyze real‑world scenarios to confidently determine CFC status and U.S. tax consequences for inbound and outbound structures.

This course qualifies for 2.5 CPE credits in Taxes.