Among the changes in the One, Big, Beautiful Bill Act (OBBBA) was the renaming of Global Intangible Low-Taxed Income (GILTI) to Net CFC Tested Income (NCTI). But the renaming is not the end of the story. The OBBBA also permanently decreases the now-NCTI deduction from 50% to 40% beginning in 2026. (Under the Tax Cuts