The long-standing Foreign-Derived Intangible Income (FDII) regime, often criticized for its complexity and its awkward treatment of tangible investments, was replaced with something simpler, more predictable, and arguably more potent: Foreign-Derived Deduction Eligible Income (FDEI).

The Global Intangible Low-Taxed Income (GILTI) regime, introduced under the 2017 Tax Cuts and Jobs Act (TCJA), was significantly revised by the One Big Beautiful Bill Act (OBBBA)—a sweeping reform package passed in 2025 that reshaped international taxation for U.S. multinationals and investors.