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GILTI is now NCTI for 2026. New 12.6% effective rate, no QBAI exclusion, better foreign tax credits. What US owners of foreign companies must do now.
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GILTI is now NCTI for 2026. New 12.6% effective rate, no QBAI exclusion, better foreign tax credits. What US owners of foreign companies must…
Read articleFDII is now FDDEI for 2026. A lower 33.34% deduction, but a bigger and simpler base. Who gains, who loses, and the 2026 exporter…
Read articleTariffs and transfer pricing pull in opposite directions. How 2026 duty changes affect intercompany pricing, customs value, and what to review now.
Read article2026 changed the repatriation math. NCTI, FDDEI, 100% bonus depreciation, and new factory write-offs change the distribute-vs-hold decision.
Read articleThe 15% corporate AMT in 2026: who it hits, the Form 4626 status test, the $800M simplified rule-out, and how CFC income and foreign…
Read articleOwn a foreign company directly? The Section 962 election lets individuals pay corporate rates on CFC income. How it works, the 2026 math, trade-offs.
Read articleDomestic R&D is deductible again in 2026, but foreign R&D still amortizes over 15 years. The retroactive window closed July 6, 2026. What to…
Read articleThe January 2026 OECD deal exempts US companies from Pillar Two's IIR and UTPR. What still applies, what to stop doing, and your 2026…
Read articleAmount B is the OECD's simplified transfer pricing method for routine distributors. Who qualifies, how the margin table works, and 2026 adoption status.
Read articleConnect with WTP Advisors to discuss your international tax and business advisory needs.