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Republican tax law leaves experts searching for words

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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.”

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Mamdani-backed socialist ousts Espaillat in NY-13

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NEW YORK — Darializa Avila Chevalier has ousted five-term House member Rep. Adriano Espaillat, the chair of the Congressional Hispanic Caucus, in a massive victory for the Democratic Socialists of America.

Her win marks another rebuke of the Democratic establishment in New York following Zohran Mamdani’s mayoral election last year, cementing the DSA as one of the city’s most potent political forces. The upset reflects a political climate in which voters have become increasingly willing to cast aside longtime incumbents in favor of outsiders promising change.

Avila Chevalier focused much of her campaign on attacking Espaillat for accepting donations from the American Israel Public Affairs Committee and real estate interests during his career.

“I really feel that this is a fight to make sure that we are representing working-class New Yorkers who have been left behind by a politics that only serves the interests of corporations, of corporate landlords, of special interest groups that are making life in New York deeply unaffordable for so many,” Avila Chevalier said last month, during an appearance with Mamdani on MS NOW where the mayor endorsed her campaign.

Espaillat, who is the first formerly undocumented person to serve in Congress, came up short despite having the support of House Minority Leader Hakeem Jeffries, Gov. Kathy Hochul, New York Attorney General Letitia James and New York City Council Speaker Julie Menin.

Avila Chevalier, 32, was a leading organizer in the pro-Palestinian encampment at Columbia University in 2024 and is a sociology Ph.D. student at the CUNY Graduate Center. She has served as an investigator for a public defender’s office and is originally from South Florida.

For most of the race, Espaillat was widely viewed as the favorite, but Mamdani’s late May endorsement of Avila Chevalier jolted a contest that began to show signs it was tightening. An April poll from Avila Chevalier’s campaign showed her down 14 points.

Her victory came despite intense outside spending in support of Espaillat, including from the Congressional Hispanic Caucus’ campaign arm.

Avila Chevalier’s election to New York’s 13th district also shows a changing of the guard in Upper Manhattan and parts of the Bronx. Espaillat has served at the helm of a political alliance, known as the “Squadriano,” that has ruled over those areas of the city, home to large Dominican American and African American populations.

At times during the race, Espaillat and his supporters sought to frame the primary battle as a contest between gentrifiers and long-term residents.

“Those that choose or want to parachute in, after the men and women of this city, the working men and women of the city, have built our neighborhood, we’re gonna send them back home packing wherever they came from,” the 71-year-old member of Congress said last month.

The story of his political ascendance and reign in Upper Manhattan has also been characterized by an intense rivalry with Manhattan Democratic Party Chair Keith Wright, an ally of the late Rep. Charles Rangel, whom Espaillat challenged for Congress in 2012 and 2014.

But this year’s primary seems to have calmed the bitter rivalry between Espaillat and Wright amid the encroachment of the Democratic Socialists of America on disputed turf. Earlier this month, Espaillat endorsed Wright’s son , state Assemblymember Jordan Wright, who was also facing a DSA-backed challenger.

The peace pact wasn’t enough to fend off the challenge from Avila Chevalier, who seized on a progressive swing in the district ever since Mamdani handily beat former Gov. Andrew Cuomo in the mayoral primary there.

“We have come a long way from where we used to be as a party,” Mamdani said in the interview where he announced his endorsement of Avila Chevalier. “It’s time we have a new generation that not only takes us back to that ambition, but takes us forward to the tomorrow that so many New Yorkers are waiting for.”

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Former Utah Rep. Ben McAdams is on track to return to Congress

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Former Rep. Ben McAdams won his primary Tuesday, paving the way for his return to Congress.

McAdams, a moderate, staved off a roster of progressive challengers in Utah’s newly redrawn 1st District, a rare deep-blue Salt Lake City district in a deep-red state that came as a result of a messy, decadelong redistricting saga.

McAdams will enter November as the heavy favorite in a district former Vice President Kamala Harris won by nearly 24 points in 2024.

McAdams won a GOP-leaning seat in the 2018 Democratic wave and governed as a centrist, Blue Dog Democrat who pushed for a balanced budget amendment — but he lost his reelection bid in 2020. He was one of the first Democrats to signal interest in running in the new 1st District and quickly garnered support from Utah elected officials and national centrist Democrats.

His progressive opponents attempted to paint him as too conservative, pointing to his previous mixed record on abortion. One opponent, state Sen. Nate Blouin, called on the other candidates to consolidate their support behind one person to avoid splitting the progressive vote. None agreed, and McAdams — who raised more money than the three other Democrats combined — prevailed.

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Trump’s preferred candidate wins primary to succeed Elise Stefanik

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ALBANY, New York — President Donald Trump’s preferred candidate to succeed Rep. Elise Stefanik cruised to victory in his Republican primary Tuesday evening.

Anthony Constantino, the CEO of custom sticker company Sticker Mule, defeated Assemblymember Robert Smullen, a retired Marine colonel, for the nomination in a deep red upstate New York House district.

Trump, along with MAGA figures Roger Stone and former New York City Mayor Rudy Giuliani, backed Constantino’s bid, casting aside Smullen’s endorsement from the New York Republican Committee.

Constantino’s victory underscores the power of Trump’s endorsement in a district he has won during each of his three presidential campaigns. His win also highlights how a candidate who’s fashioned himself in a MAGA mold can continue to resonate in a largely rural and predominantly white district that has struggled economically for decades.

A former boxer, Constantino has dabbled in music, producing songs that praise Trump. He initially drew Stone’s attention after erecting a large “Vote for Trump” sign on a building in Amsterdam, N.Y., a city less than an hour west of Albany. Constantino also gifted Trump a bronze statue in the president’s likeness.

The circus-like primary became a bruising battle between a first-time candidate who channeled Trump-style promotion and attacks against an establishment favorite with a long, accomplished resume.

Constantino referred to Smullen as “Slime Bob” and called him “evil” in a text message to his rival. Smullen, in turn, called Constantino “unfit” and knocked his prior enrollment as a Democrat.

The race became so bitter that Smullen refused to shake Constantino’s hand at the conclusion of their only televised debate.

Constantino poured $10 million of his own money into the race and spent more than $3.8 million on TV ads, saturating upstate media market airwaves. Smullen’s campaign spent a fraction of that amount, more than $500,000 in ad spending, according to the tracking firm AdImpact.

The sticker impresario also displayed a marketing flare, printing t-shirts that touted his Trump endorsement.

Smullen leaned heavily on his biography and background as a combat Marine. But he often found himself responding — sometimes angrily — to Constantino’s barrage of attacks.

Constantino will now have to make peace with some New York power brokers as he pivots to the general election. Smullen is set to remain on the November ballot with the backing of the state Conservative Party’s ballot line. Constantino is being sued for defamation by that party’s leader, Jerry Kassar.

The House seat opened after Stefanik, who has represented the area for more than a decade, announced she would leave Congress after scuttling her gubernatorial campaign. Stefanik was previously Trump’s nominee for United Nations ambassador, but that was yanked amid concerns her vacancy would complicate the House Republicans’ narrow majority.

Stefanik did not endorse in the race to replace her.

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