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).

A summary of the key changes to the U.S. international tax regime introduced by the One Big Beautiful Bill Act of 2025 (Budget Reconciliation Bill).