The One Big Beautiful Bill Act, signed on Jul. 4, 2025, includes changes that apply to controlled foreign corporations and their US shareholders. Two of those changes affect whether a US taxpayer has a Form 5471 filing requirement and an income inclusion for a foreign corporation’s subpart F income or net Controlled Foreign Corporations (CFC) tested income—the new name for global intangible low-taxed income. The changes are effective for foreign corporation tax years beginning after Dec. 31, 2025.