Section 250

Final FDII Regulations Released

July 16, 2020 By Edward Tanenbaum, Richard Slowinski and Stefanie Kavanagh

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. [...]Read more

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.

[...]Read more

GILTI Basis Adjustments

November 2, 2018 By Jasper L. (Jack) Cummings, Jr.

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.

Read the full advisory here.