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US Final FDII regulations retain proposed regulations’ structure, but reduce documentation burden, defer effective date and make important substantive changes to the computation of Section 250 deduction

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United States

On 9 July 2020, the United States (US) Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released final regulations under Internal Revenue Code (IRC)1 Section 250 (Treasury Decision 9901) for calculating the deduction allowed to a domestic corporation for its foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI). The final regulatio…

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