Most companies plan to roll last year’s international tax spreadsheet forward. For 2026, that’s not enough: several of the mechanics connecting Subpart F, GILTI, the section 250 deduction, foreign tax credits, section 163(j), and BEAT changed at the same time, and CAMT’s guidance shifted right alongside them.
GILTI is now Net CFC Tested Income (NCTI): the QBAI-based deemed tangible income return is gone, and the section 250 deduction drops from 50% to 40%, pushing the effective rate on NCTI from 10.5% to 12.6%. FDII becomes FDDEI, with its own section 250 rate cut (37.5% to 33.34%, effective rate up to 13.9986%) and a redefined deduction-eligible income base. Foreign tax credit utilization improves: the section 960 deemed-paid haircut on NCTI drops from 20% to 10%, and fewer expenses (interest, R&E) are allocated against the NCTI basket. Subpart F’s look-through rule is now permanent and the “last day” ownership rule is gone. Section 163(j)’s ATI calculation reverts to the more favorable pre-2022 EBITDA method. BEAT stays fixed at a 10.5% rate.
CAMT didn’t get an OBBBA-style statutory overhaul, but its guidance moved substantially. Notice 2025-27 introduced an optional simplified method using $800 million / $80 million thresholds, and Notice 2026-7 layered on further interim clarity. Every US corporation still has to complete Form 4626, Part I, to determine applicable-corporation status, even one that ultimately isn’t subject to CAMT, and that determination draws on the same CFC ownership, income, and foreign tax data already needed for Subpart F, NCTI, and FTC.
That’s the real 2026 story: these calculations were never truly separate, and now they’re more interconnected than ever. A change in one ripples into the others, and a model built to handle them in isolation is going to miss something.
Orbitax International Tax Calculator runs Subpart F, NCTI, section 250, FTC, section 163(j), and BEAT end-to-end on one common dataset, fully aligned with the 2026 rules, with an audit trail from inputs to final results, and CAMT is being built into that same process, connected to the Pillar Two calculations on the Orbitax platform.
Talk to us about what a 2026-ready model looks like for your organization.