US Expats With Foreign Companies Face New Tax Rules Starting 2026

YORK, United Kingdom, Sept. 28, 2026 /CourierPR/ -- The United States has introduced new international tax rules for US expatriates and Green Card holders who own or control businesses overseas, effective from tax years beginning after December 31, 2025. This shift from the former Global Intangible Low-Taxed Income (GILTI) regime to the new Net CFC Tested Income (NCTI) regime marks a significant change that could impact these individuals and their tax obligations.

According to Darryl Albuquerque, Senior Tax Manager at Expat Tax Online, the transition is more than just a name change. The new rules bring several notable changes, including the elimination of QBAI, which is no longer used to reduce the amount subject to Section 951A. Additionally, the Section 250 deduction is reduced from 50% to 40%.

The new regime also improves the foreign tax credit treatment, with the deemed-paid foreign tax credit percentage increasing from 80% to 90%. For calendar-year taxpayers, an important timing distinction applies: tax returns for 2025 filed in 2026 will generally still use the GILTI rules, while the new NCTI rules will apply to the 2026 tax year. The outcome for affected taxpayers can vary depending on their company’s foreign tax rate, income, ownership structure, and whether a Section 962 election is used.

Expat Tax Online, the most trusted US expat tax service for Americans living abroad, offers specialist support for US tax returns, FBARs, foreign trusts, and other international tax reporting requirements. With more than 10,000 positive reviews from US expats, the global tax firm focuses exclusively on helping Americans abroad manage their US tax obligations. Clients in more than 150 countries rely on the firm to navigate the complexities of international tax law.