Republican tax law leaves experts searching for words

Politico

3 days ago

At the same time, it remains to be seen whether Republicans' decision to dub their new savings accounts for children 'Trump accounts' will prove a marketing misstep that will blunt its appeal to the 75 million Americans who voted for Kamala Harris.
The overall legislation was christened by Trump, but the 'One Big Beautiful Bill Act' was scrubbed from the legislation once it got to the Senate, after Democratic leader Chuck Schumer had it struck as a violation of the chamber's internal rules — the latest shot in a long-running feud in which the two parties take turns deleting the names of each other's reconciliation bills.
'I just forced Republicans to delete their ridiculous bill name,' Schumer wrote shortly thereafter on X. 'Nothing about this bill is beautiful.'
Technically the legislation is now called 'An act to provide for reconciliation pursuant to title II of H. Con. Res. 14.'
Of course, that isn't stopping many from still using the now-unofficial name. 'One Big Beautiful Bill Act' was the winner in a recent EY survey of 10,000 tax pros asking how they referred to the tax law. 'OB3" came in a close second. A similar survey by Grant Thornton also had those names going one-two.
Over at the Tax Policy Center, senior fellow Howard Gleckman prefers the colloquial '2025 budget act' or, simply, 'the big budget bill.' The studiously nonpartisan Congressional Budget Office, meanwhile, uses the extremely neutral 'H.R. 1.'
Some of the individual provisions have been renamed to reflect substantive changes made by the legislation.
'GILTI' was made obsolete by Senate Republicans' revisions to how multinationals will be taxed.
The original tax was intended to target profits from things like patents that businesses squirreled away in tax havens. Republicans had trouble coming up with a way of legally defining those earnings, so in the 2017 law they essentially said GILTI was everything except profits resulting from tangible assets like factories.
The idea was to distinguish between the money companies made from their actual operations abroad from things that were just accounting maneuvers. Naturally, the tangible stuff got its own acronym — QBAI, or Qualified Business Asset Investment.
But the new law dumps QBAI, and so the distinction made by GILTI no longer matters, leaving the tax world with 'Net CFC Tested Income.'
Something similar is happening with FDII, or Foreign Derived Intangible Income, another provision that originated in 2017.
It's a deduction for companies with overseas profits from intellectual property held in the U.S. — although it's probably best known for inspiring a years-long dispute about whether it should be called 'Fiddy' or 'F-D-I-I.'
QBAI was part of the calculations that went into FDII, so, with QBAI now going away, FDII is also renamed in the new law, as the Foreign Derived Deduction Eligible Income, or FDDEI.
But if anything, it's even less clear how to shorthand that.
Warren Payne, a former Republican tax aide now at the firm Mayer Brown, says he's heard it called 'Fa-Day' — though he's not going there.
'I haven't figured out how to pronounce it,' he said. 'I just spell it out.'