
Subpart F Income and CFC Rules: U.S. Tax on Foreign Corporation Profits Under NCTI in 2026
How U.S. shareholders of foreign corporations are taxed on undistributed profits in 2026: the 10 percent threshold, Section 958 constructive ownership, Form 5471 filing duties, and the OBBBA rewrite that replaced GILTI with Net CFC Tested Income (NCTI).










