Cross-border deal structuring after OBBBA means baking the reworked international regime—NCTI, FDDEI, BEAT, and the EBITDA-based Section 163(j) limitation—into the model, layering the Pillar Two overlay onto purchase-price allocations and deferred-tax positions, and working through the Section 367(a) and (b) toll charges, Section 7874 anti-inversion rules, and withholding traps that shape inbound and outbound acquisitions alike. Against that backdrop the panel gives particular attention to redomiciliation: despite a competitive U.S. rate, an onshoring push, and Notice 2025-45's easing of the FIRPTA hurdles to inbound F reorganizations, domestications still remain relatively rare. Section 367(b)'s all-E&P toll charge and Section 7874 keep coming (and staying) home expensive. The panel will discuss the latest state of play and what reforms could actually move the needle.