Treasury and IRS propose regulations to implement NCTI and FDDEI expense apportionment provisions in OBBBA

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10 September 2026

Treasury and IRS propose regulations to implement NCTI and FDDEI expense apportionment provisions in OBBBA

The Treasury Department and IRS on September 10, 2026, proposed regulations (REG-117273-25) under IRC Sections 904(b)(5) and 250(b)(3) that would implement provisions of the "One Big Beautiful Bill Act" that limit deductions allocable to Net CFC Tested Income (NCTI) and Foreign-Derived Deduction-Eligible Income (FDDEI). A Tax Alert is forthcoming.

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Published by NTD’s Tax Technical Knowledge Services group; Chris DeZinno, legal editor

Document ID: 2026-1931

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