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U.S. tax rules replace GILTI with NCTI, cutting Section 250 deduction to 40%

Verifying
  • U.S. tax rules replace GILTI with NCTI for qualifying tax years.
  • 40% Section 250 deduction and 90% foreign tax credit treatment generally apply under NCTI.
  • Calendar-year 2025 returns filed in 2026 generally still use GILTI rules.
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