July 1, 2025
When the NCTI Tax Structure Actually Works – and When It Absolutely Doesn’t
Q: Can the 10.5% Net CFC Tested Income (NCTI) regime really beat an S-Corp for a small-business owner? A: Only in very specific circumstances. Under the Net CFC Tested Income (NCTI – formerly GILTI), the structure can win if you’re a high-earning US expat who (1) routes profits through a US C-Corp that owns a bona fide foreign subsidiary, (2) […]