The One Big Beautiful Bill Act (OBBBA) makes several law changes that will impact the international tax regime, including GILTI (now "Net CFC Tested Income"), BEAT, and FDII. From an accounting methods perspective, the computation of the earnings and profits (E&P) of a controlled foreign corporation will continue to be important for its U.S. shareholders for both federal income tax planning and compliance purposes. For example, the calculation of GILTI (now "Net CFC Tested Income") and “subpart F” income require a foreign corporation to determine E&P using U.S. tax principles, including proper methods of accounting and tax elections. A change to a foreign corporation's accounting methods requires E&P to be adjusted by the “catch up” adjustment under section 481, in the same manner that a method change and section 481 adjustment impacts a domestic corporation's taxable income. Thus, a foreign corporation may file a method change to reduce E&P thereby reducing a subpart F income or GILTI inclusion' in a particular year and/or to increase foreign tax credits associated with a distribution or inclusion.