FDII or Not: Section 250 FDII and GILTI Deduction Regulations Proposed

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The IRS and Treasury’s proposed regulations on the Section 250 deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI) tackle several questions left unanswered by the 2017 tax law. Our International Tax Group highlights key takeaways from the complex, near-algebraic, proposed rules.

  • Section 250 alphabet soup: FDII, GILTI, QBAI, DEI, FDDEI
  • GILTI deduction allowed for Section 962 election taxpayers
  • A few questionable answers for FDII issues

Read the full advisory here.