Section 250
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 corporationsA more relaxed and flexible approach to documentation and substantiation requirementsClarification for the software industry on foreign use of digital sales and advertising
Read the full advisory here.
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FDII or Not: Section 250 FDII and GILTI Deduction Regulations Proposed
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.
GILTI Basis Adjustments
Our Federal Tax Group explores how Treasury’s proposed regulations could have the global intangible low-taxed income (GILTI) regime operating in a way you might not expect.