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

March 15, 2019 By Edward Tanenbaum, Jasper L. (Jack) Cummings, Jr. and Heather Ripley

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.

 

Filed Under: International Tax Advisory Tagged With: DEI, FDDEI, FDII, GILTI, QBAI, Section 250, Section 962, tax reform, TCJA

About Edward Tanenbaum

Edward Tanenbaum is co-chair of the firm’s Federal & International Tax Group and a member of the firm’s Global Resources & Strategies Committee. Mr. Tanenbaum’s practice consists primarily of planning and structuring tax efficient solutions for cross-border business transactions and investments by foreign multinational corporations and high-net-worth individuals.

[Read Bio]

About Jasper L. (Jack) Cummings, Jr.

Jack Cummings is counsel in the Federal Tax Group of Alston & Bird in Raleigh and Washington, D.C. He served as IRS associate chief counsel (corporate) and chair of the Corporate Tax Committee of the ABA Section of Taxation.

[Read Bio]

About Heather Ripley

Heather Ripley is an associate in the firm’s Federal & International Tax Group. Her practice focuses on federal and international tax services for a range of clients, including domestic and international business entities and individuals.

[Read Bio]

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