2026 International Tax Update: Navigating New Rules for U.S. Taxpayers Overseas

As the 2026 tax year begins, U.S. taxpayers with foreign operations face a fundamentally reshaped landscape. The "One Big Beautiful Bill Act" (OBBBA) has moved several temporary provisions into permanency while rebranding and modifying core international regimes like GILTI and FDII.

This session, led by international tax authority Patrick McCormick, provides a deep dive into these structural changes. From the elimination of the QBAI offset to the new "Side-by-Side" proposal for the global minimum tax, we will explore how to maintain compliance and optimize tax positions under the new 2026 standards.

Learning Objectives:

By the end of this session, participants will be able to:

Identify the key structural changes to the GILTI (now NCTI) and FDII (now FDDEI) regimes effective for 2026.
Analyze the impact of the repeal of the Qualified Business Asset Investment (QBAI) offset on capital-intensive foreign operations.
Explain the updated reporting requirements and the restoration of Section 958(b)(4) for Controlled Foreign Corporations (CFCs).
Determine how the U.S. "Side-by-Side" proposal interacts with the Global Pillar Two minimum tax framework.
Evaluate planning strategies for foreign tax credit (FTC) optimization under the reduced 10% haircut.

Session Highlights:

The Rebranding & Restructuring of Anti-Deferral Regimes.
Strategic Foreign Tax Credit (FTC) Optimization.
Structural Compliance & Ownership Changes
Global Minimum Tax (Pillar Two) Interaction.
Operational Benchmarking & Asset Placement.
Trend Analysis: The 2026 "Audit Wave"

Who Should Attend

CPAs & Enrolled Agents
Bookkeepers
Small Business Owner
Tax Managers

Credits and Other information :

IRS CPE Credits: 2.0 TAX

Location: Virtual/Online

Delivery method: Group Internet Based

IRS Course ID: DFFSC

Attendance Requirement: Yes

Session Duration: 2 Hours

Case Studies and Live Q&A session with speaker

PowerPoint presentation for reference

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