Alston & Bird Tax Blog

Final FDII Regulations Released

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Talk about a summer beach read… The IRS’s final regulations for Section 250 deductions for FDII and GILTI are here for your light summer reading. Better yet, let our International Tax Group explain it all for you.

  • The Section 250 deduction generally applies to domestic C corporations
  • A more relaxed and flexible approach to documentation and substantiation requirements
  • Clarification for the software industry on foreign use of digital sales and advertising

Read the full advisory here.

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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.

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About Richard Slowinski

Richard Slowinski is a partner in the Federal & International Tax Group. For more than 25 years, he has advised clients on tax matters, with a focus on transfer pricing. Richard’s international clients span multiple industries, including transportation, finance, hospitality, electronics, aerospace, pharmaceuticals, and retail.

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About Stefanie Kavanagh

Stefanie Kavanagh is an associate in the Federal & International Tax Group. She focuses her practice on tax planning and structuring for domestic and international business entities as well as matters relating to real estate investment trusts.

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