Official Site of The State of New Jersey

Federal Renaming for GILTI and FDII Under the One Big Beautiful Bill Act for Corporation Business Tax

For Tax Years beginning after December 31, 2025, the federal “One Big Beautiful Bill Act” (OBBBA, P.L. 119-21) renames GILTI (Global Intangible Low Tax Income) as Net Controlled Foreign Corporation Tested Income (NCTI), and FDII (Foreign Derived Intangible Income) as Foreign-Derived Deduction Eligible Income (FDDEI), for federal purposes. The treatment of these concepts for New Jersey Corporation Business Tax purposes is unchanged and remains as set forth in the published guidance and regulations. When reviewing prior materials, keep in mind that any reference to GILTI refers to NCTI and any reference to FDII refers to FDDEI.