The numbers
The numbers
What the election does to the rate
The headline benefit is rate, deduction, and credit working together. The figures shifted for tax years beginning after 2025 under the OBBBA — here is the before-and-after on GILTI / NCTI.
| On GILTI / NCTI income | No electionindividual | §962 — TY 2025GILTI | §962 — TY 2026+NCTI · OBBBA |
|---|---|---|---|
| Tax rate applied | up to 37% | 21% | 21% |
| §250 deduction | none | 50% | 40% |
| Effective rate before credits | up to 37% | 10.5% | 12.6% |
| Deemed-paid foreign tax credit | none | 80% | 90% |
| QBAI carve-out | — | 10% | eliminated |
| Foreign rate to zero out U.S. tax | — | ≈ 13.1% | ≈ 14% |
Individual rates also may carry the 3.8% net investment income tax. Figures are general; the actual result depends on the CFC’s country, its foreign effective rate, and expected distributions.