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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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Congress

‘I’ve been taking a ton of risk’: Inside Jim Himes’ mission to save a key spy authority

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Jim Himes wants to reauthorize a controversial surveillance law. He knows it comes with big risks.

The top Democrat on the House Intelligence Committee has been seeking a bipartisan deal to extend Section 702 of the Foreign Intelligence Surveillance Act while Republicans are busy fighting among themselves over how to prevent the government spy power from expiring April 30.

Fearing a lapse would be an existential crisis, he’s been empowered by House Minority Leader Hakeem Jeffries to share his perspective with fellow Democrats who are skeptical of reauthorizing Section 702 without guardrails to protect Americans from being targeted by the Trump administration. And despite his own preferences for modifying the spy authority, he’s facing criticism from progressives in his district for being open to a clean extension.

Himes has also been talking to the White House — but often finds himself out of the loop of negotiations with House Republican leaders, who are more focused on trying to squeeze a deal through their ultrathin margins than find common ground with Democrats.

“There’s been a shit ton of outreach to me” on this issue, Himes, of Connecticut, said in a lengthy interview in his Capitol Hill office Thursday. “None of it has been, ‘Come to this room to negotiate this deal today.’”

Himes is reflected in a mirror during an POLITICO in his office on Capitol Hill in Washington, on April 23, 2026.

The stakes are high for Himes as he navigates the difficult politics around a surveillance law viewed with deep suspicion by many progressives and conservatives. And in attempting to broker cross-party consensus around the spy law, he has embarked on a potentially thankless mission.

He’s challenging Republicans’ appetite for bipartisan dealmaking in the Trump era — and so far, he’s being largely ignored by the GOP leaders. He’s also testing whether Democrats would attach their names to any legislation that gives even the appearance of emboldening an administration they view as corrupt — and it’s getting more difficult by the day.

“I’ve been taking a ton of risk, I’ve been doing a ton of explanations,” Himes said later Thursday.

If he succeeds in stitching together some fractured coalition to extend Section 702 with meaningful guardrails, he will have pulled off a feat of political compromise rarely seen these days. But if he is unable to help land a deal and must instead back a clean extension in the interest of protecting national security, he will undoubtedly take fresh heat from progressives, perhaps in the form of a credible primary challenger.

One long-shot candidate looking to unseat Himes in the Democratic primary based on the incumbent’s FISA stance — Joseph Perez-Caputo, a local activist — has been leading constituent protests against the lawmaker back home.

“We’ve kind of watched in abject horror,” Perez-Caputo said in an interview of Himes’ scramble to land a Section 702 agreement.

A new letter from half a dozen groups in Connecticut, shared first with Blue Light News, is calling on Himes to step down as the Intelligence Committee’s ranking member, saying he has “betrayed” obligations to his constituents and the Constitution — including by “actively lobbying other Democrats and Republicans to support the administration’s FISA agenda.”

CIA Director John Ratcliffe, left, shakes hands with Himes during a House Select Intelligence Committee hearing in Washington to assess worldwide threats, March 19, 2026.

Himes is cognizant of the dynamics, recalling that he got his “head blown off” by frustrated participants during a demonstration in his district last month, adding, “there’s an immense amount of misinformation out there that needs to be addressed.”

Ultimately, Himes says, he’s driven in this fight by a sense of duty. Over the course of the Thursday interview, he insisted — repeatedly — that he prefers extending the spy authority with policy changes, like seeking judicial review for searches under the program, to continuing on with the status quo.

Rather, Himes explained, his perch on the Intelligence panel uniquely positions him to understand the scope and stakes of a Section 702 expiration. And if it were to come down to a choice between passing a clean extension or letting the program expire, a lapse would be a nonstarter.

“Three months from now, if FISA 702 is dark and there’s a bomb in Grand Central, there will be very little doubt in my mind … that that occurred because we shut down our most important counterintelligence,” Himes said.

“So I don’t blame them,” he added of those members who would prefer the program lapse than support a clean extension. “But I just see with some granularity — actually, more granularity than pretty much anybody around here — what the risks are that we face.”

Despite Himes’ entreaties, many House Democrats remain skeptical. Rep. Stephen Lynch of Massachusetts said in an interview Thursday he will vote against a reauthorization for the first time in his 25-year tenure in the House if the legislation does not institute new guardrails on warrantless government surveillance.

Personal items are seen in Himes' office on Capitol Hill in Washington, April 23, 2026.

Congressional Progressive Caucus Chair Rep. Greg Casar (D-Texas) said he respects Himes and appreciates that he has attended caucus meetings to share his perspective on the issue. But, he said in an interview, the decision was an easy one: “We should unify now to say, ‘No, Trump does not use power responsibly.’”

Himes said his senior role on the House Intelligence Committee means he’s inclined to never trust any administration — and he “particularly” doesn’t trust this one. But he emphasized he has not, in his role on the panel, ever been presented with any evidence that President Donald Trump or senior White House officials have sought to interfere with Americans’ privacy.

“In the last 14 months,” he said, “there has not been a single example of their attempt to abuse this database. I am conscious of something that is hard to get people to understand, which is, there is no program that is more overseen than this one. None.”

Rep. Gregory Meeks of New York, the top Democrat on the Foreign Affairs Committee who is also privy to classified information not shared with the majority of his colleagues, had a similar point of view.

“I don’t want it to be on my conscience that something happens that we could have stopped,” Meeks said in an interview. “That’s the responsibility that Jim has and the burden at times of being the ranking member, and the former chair, of Intel.”

Some Republicans downplayed Himes’ role in the FISA talks as GOP leaders go down a partisan path. House Intelligence Chair Rick Crawford questioned how much Himes is backchanneling with Republicans, while noting he considers the ranking member a friend.

“We try to be considerate of him and his concerns, and I think he extends me that courtesy as well,” the Arkansas Republican said in an interview Thursday. “So we have a good working relationship. And I think that’s helpful.”

Himes arrives for an interview with POLITICO in his office on Capitol Hill in Washington, April 23, 2026.

As the April 30 deadline to extend the FISA spy authority draws nearer, Himes is continuing to make the rounds with colleagues of both parties but also think strategically about what could pass the House, and how.

He and the senior House Judiciary Democrat, Rep. Jamie Raskin of Maryland, have been workshopping possible backup plans with policy changes that could attract more Democratic support in case Republicans fail to pass their partisan bill.

He’s now also interested in finding a set of reforms that could get the support of a two-thirds majority of the House so that the legislation could advance under an expedited floor procedure known as a suspension, which doesn’t first require clearing a party-line “rule” vote.

Himes said there was a “real opportunity” to pass a bill under suspension last week, when Speaker Mike Johnson instead attempted, unsuccessfully, to pass an 18-month extension bill through the regular order process in the middle of the night. But Johnson’s failure, Himes continued, only emboldened Democrats to stand back and watch the GOP flounder.

Calling himself an “emissary” during that overnight vote, Himes was frank: “A bunch of members at two in the morning, watching the speaker fall flat on his face, does not help me.”

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Mike Johnson tries again to extend contested spy law

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House GOP leaders on Thursday unveiled the text of a new three-year extension of a key spy law, as Speaker Mike Johnson tried to overcome ultra-conservative resistance and pass it next week.

The proposed reauthorization of the so-called Section 702 law includes some new oversight and penalties for abuses of the spy authority but stops short of warrant requirements sought by GOP hard-liners.

Conservatives have pushed back on extending Section 702, which allows warrantless surveillance of foreigners, because of concerns about U.S. citizens being caught up in the program.

The faction that’s been opposing an extension has not yet signed off on the latest plan. GOP leaders plan to continue talks into the weekend.

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House GOP leaders scramble to sell Senate’s slimmed-down budget with promises of ‘Reconciliation 3.0’

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House Republican leaders want a floor vote next week on the Senate’s budget resolution, the first step in writing an immigration enforcement bill and passing it by President Donald Trump’s June 1 deadline.

“It has to be clean because it has to be quick,” Speaker Mike Johnson said Thursday, indicating that conservatives could not make major changes to the other chamber’s blueprint at this time.

But Johnson and others still have to lock in support from conservatives who are threatening to vote against it if it doesn’t encompass more top GOP policy priorities, and it is proving to be a delicate balancing act.

House Majority Leader Steve Scalise (La.) met Thursday morning with Budget Chair Jodey Arrington (Texas) and leaders of key House GOP factions, according to four people granted anonymity to share details of private meetings — an effort to quell concerns among some conservatives about the narrow scope of the current plan. Arrington and other senior Republicans have been pushing to expand the party-line bill currently under discussion.

Johnson, Scalise and others in GOP leadership are promising that as soon as Republicans pass a bill funding immigration enforcement and some border patrol activities, they will get to work on another measure through the filibuster-skirting budget reconciliation process.

“We’re going to move right to reconciliation, what will now be 3.0,” Johnson said, referring both to the current plan and the tax and spending megabill Republicans passed last summer. “We’re going to do it as quickly as possible.”

Some of the ideas that circulated during the closed-door leadership meeting Thursday included opening up the possibility for more tax policy changes, addressing the Trump administration’s request for $350 billion for the Pentagon, additional funding for the Iran war and spending cuts across social programs in another package.

Arrington, who is among those wishing to expand the upcoming reconciliation effort, is seeking steep spending reductions to social programs and hopes to revisit Obamacare spending — including cost-sharing reductions, which would reduce out-of-pocket health costs.

Leadership of the Republican Study Committee, meanwhile, is demanding that any third reconciliation bill be fully paid for. There has been limited angst over “pay-fors” for the current party-line pursuit because the measure is an attempt to fund the immigration enforcement agencies and circumvent regular appropriations negotiations, which have been stuck for months.

But many Republicans are doubtful their party will be able to pass another party-line bill ahead of the midterms and see the immigration funding bill as their last bite at the apple. Some of them, including Rep. Warren Davidson of Ohio, are threatening to vote against the Senate budget resolution that would unlock the reconciliation process for the immigration funding measure unless it can incorporate more items from the hard-liners’ wishlist.

GOP leaders are now scrambling to stave off defections. Adoption of identical budget resolutions in both chambers will unlock the ability for lawmakers to write and pass a bill through reconciliation that would send tens of billions of dollars to immigration enforcement operations run through the Department of Homeland Security, which has been shuttered since February.

Republicans are on a very tight schedule to send this bill to Trump’s desk and pave the way for ending the record-setting DHS shutdown, given White House demands.

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