Eversheds Sutherland Tax Reform Law Blog
content top

IRS Releases Proposed Regulations Addressing the FDII and GILTI Deduction under Section 250

On March 4, 2019, the IRS released proposed regulations under section 250. Section 250 generally allows a domestic corporation a deduction for its foreign-derived intangible income (FDII) and its global intangible low-taxed income (GILTI). The proposed regulations provide rules for determining the amount of the deduction, including guidance related to the provision’s taxable income...