What the “One Big Beautiful Bill” Means for Cross-Border Private Clients: Not Much — But Here’s What to Watch

Author: Milan Solarz-Patel

Founder & Chief Tax Advisor, Auric Private Client Advisory LLC

Photo by Louis Velazquez on Unsplash

The One Big Beautiful Bill Act (“OBBB”), signed into law on July 4, 2025, has drawn attention for its wide-ranging changes to the international tax framework governing U.S. multinationals. Yet, for cross-border private clients—families, trustees, and advisors managing wealth across jurisdictions—the legislation offers little in the way of direct impact. Despite its breadth, the OBBB largely bypasses the core concerns of international private clients.

This article reviews the OBBB through a private client lens and highlights a handful of provisions that may warrant a closer look, even if only at the edges of typical wealth management structures.

1. The Corporate-Centric Nature of the OBBB

The OBBB is emphatically targeted at corporate taxpayers. Its key provisions—revisions to the global intangible low-taxed income (GILTI) regime, the foreign-derived intangible income (FDII) deduction, foreign tax credit limitations, and controlled foreign corporation (CFC) attribution rules—apply primarily to U.S. corporations engaged in global business operations.

Most private client structures, including passive foreign investment vehicles and non-operating family holding companies, are generally unaffected.

Takeaway:

Unless the client structure includes an operating CFC with a U.S. corporate shareholder, the headline provisions of the OBBB do not apply.

2. Foreign Trusts: Not Even a Footnote

The OBBB leaves the U.S. tax treatment of foreign trusts entirely untouched. There are no modifications to grantor trust rules, accumulation distributions, the throwback tax, or the interest charge on undistributed net income (UNI). Reporting obligations under Forms 3520 and 3520-A remain unchanged.

Takeaway:

Private clients relying on non-U.S. trusts will see no legislative change—favorable or unfavorable.

3. Restoration of Section 958(b)(4): Relief from Unintended CFC Status

The restoration of former section 958(b)(4), reversing the downward attribution rule introduced by the 2017 Tax Cuts and Jobs Act, is a welcome clarification. The repeal of that provision had unexpectedly expanded the scope of CFC status to foreign companies with only indirect U.S. ownership via trusts or partnerships—often catching private client structures in the crossfire.

Who benefits:

U.S. beneficiaries of foreign family businesses or funds where no direct U.S. control exists. These structures may now fall outside CFC status once again.

4. 1% Excise Tax on Remittance Transfers: Limited Private Client Exposure

The OBBB introduces a 1% excise tax on certain cross-border electronic remittance transfers initiated by senders in the United States. However, the tax does not apply to transfers made through insured financial institutions or using U.S.-issued debit or credit cards—conditions that encompass most private banking channels.

Watchpoint:

Clients relying on money transfer businesses or alternative payment platforms may wish to confirm whether their remittance activity triggers the new tax.

5. No Revisions to PFIC, Trust, or Inbound Investment Regimes

The OBBB does not address the taxation of passive foreign investment companies (PFICs), foreign nongrantor trusts, or U.S. inbound investment vehicles held by nonresidents. Advisors concerned about reforms to sections 1291–1298, the throwback regime, or treaty-based structuring can rest easy—for now.

6. Treaty Access and Re-Sourcing Rules: Status Quo Maintained

Taxpayers using hybrid or transparent structures to access treaty benefits—such as Luxembourg S.A.R.L.s or U.K. LLPs—will note with relief that the OBBB makes no changes to U.S. sourcing rules or treaty override provisions. Re-sourcing rules for foreign tax credits also remain intact, with only narrow technical corrections.

---

Despite its sweeping scope, the OBBB is largely silent on the issues that matter most to cross-border private clients. For wealth advisors, trustees, and tax counsel, the most significant outcome may simply be the absence of change. That said, a few provisions—including the reinstatement of section 958(b)(4), the remittance excise tax, and potential indirect effects of corporate tax shifts—deserve measured attention.

The OBBB may be a transformative piece of legislation for multinational enterprises, but for private clients, it is more of a non-event. And in the world of cross-border tax, sometimes no news is good news.