As the tax world pores over Republicans’ tax cuts, one question keeps coming up: What are we calling this?
In a town that loves clever acronyms, tax pros are struggling to figure out how to talk about the new law, beginning with its name. The official title, at least before Democrats had it deleted from the legislation, is a mouthful: the One Big Beautiful Bill Act. And it’s a bit awkward with the word “act” following “bill.”
But there’s no consensus on what else to call it.
Treasury Secretary Scott Bessent likes “O Triple B.” Others are going with “OBBB” or “TOBBB” or “OBBBA” or “BBB.” “OB3” has been getting some traction, which bugs Libin Zhang, a tax lawyer at Fried Frank.
“’OB3’ is a bit misleading because the 3 should come before the B, like ‘O3B’,” he says. Zhang likes “OB-cubed.”
It’s not just the title that has experts tongue tied.
The legislation has an alphabet soup of provisions that are also scrambling the tax lexicon, simultaneously adding new terms and acronyms while deleting others — including GILTI, perhaps the most well-known piece of jargon to emerge from Republicans’ original 2017 tax cuts.
The Global Intangible Low-Taxed Income tax is a special levy Republicans imposed on business profits parked in overseas tax havens, and the acronym left little doubt about the dim view lawmakers took of the tactics.
But GILTI is being scotched by the new law, replaced by “Net CFC Tested Income” (NCTI) — which now has some test driving possible nicknames, including “necktie” and “neck tee.”
Others say they are sticking with GILTI regardless.
“The name GILTI is gone, although I think many of us will continue to refer to it as GILTI,” said EY’s Jason Yen, in a recent webinar on the legislation.
The struggle for words comes as experts try to wrap their heads around the legislation, signed into law a little more than two weeks ago. Much of the law was written in secret and didn’t get a lot of public vetting before passage, so the tax world is simultaneously trying to figure out what the bill does as well as what to call it.
The provision with the catchiest nickname — the “revenge tax,” a moniker some Republicans tax aides hated — didn’t make it into the final legislation. Lawmakers dropped that levy, designed to punish countries that implement a framework for taxing big multinational companies, after Bessent said it was no longer necessary, citing his negotiations with G7 nations that are part of the global pact.
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.”
