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The One Big Beautiful Bill Act renamed FDII to FDDEI, recalibrated §250, and reset the TCJA-sunset urgency narrative. We track what AI tax-planning tools get right and where they're still selling the cliff that doesn't exist.
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OBBBA renamed FDII to FDDEI and recalibrated the §250 deduction (37.5% → 33.34%, ~14% effective rate). QBAI is gone. Two new DEI exclusions hit transactions after June 16, 2025. The full TY2026 regime hits January 1, 2026. Most AI tools currently return mixed FDII/FDDEI terminology for a structural reason this article names.
OBBBA replaced the uniform 100% §1202 exclusion with a tiered 50/75/100% system at 3/4/5 years, raised the per-issuer cap to $15M, and lifted the aggregate-asset threshold to $75M — for stock issued after July 4, 2025.
OBBBA §70323 renamed GILTI to NCTI inside §951A. §70321 dropped the §250 deduction from 50% to 40%. §70323 eliminated the QBAI offset. §70312 cut the §960(d) FTC haircut from 20% to 10%. Effective for tax years beginning after December 31, 2025.