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OB3 Impacts: FDDEI Mechanics & Modeling

November 5, 2025

Join the International Tax team from Forvis Mazars for sessions focused on new legislation from the One Big Beautiful Bill Act (OB3 or OBBBA) impacting multinational enterprises (MNEs). These informative presentations are designed to deepen technical understanding and provide practical planning insights for CFOs, VPs of tax, tax directors, controllers, and those seeking to learn more about OB3.

This second session will cover the mechanics of the foreign-derived deduction-eligible income (FDDEI) deduction under the new law, including how to model benefits for service and property transactions. We’ll also explore how FDDEI interacts with key domestic tax provisions, such as bonus depreciation and Sections 174 and 163(j), and discuss strategies for leveraging FDDEI and its impact on the general category of the Foreign Tax Credit (FTC).

Learning Objectives

Upon completion of this program, participants will be able to:

  • Discuss the mechanics of the FDDEI deduction.
  • Analyze the interaction between FDDEI benefits and key domestic tax provisions.
  • Evaluate strategies for utilizing FDDEI.

Presenter(s)

Chris Clifton, Joshua Zellerman