OBBBA makes permanent several international and foreign-related provisions originally introduced under the TCJA. These include the deduction for foreign-derived intangible income (FDII), now modified and renamed as foreign-derived deduction eligible income (FDDEI), and global intangible low-taxed income (GILTI), which is now referred to as net CFC tested income (NCTI). It also retains the base erosion minimum tax amount.
