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Foreign Derived Intangible Income (FDII) Controlled Foreign Corporations Proposed Regulation

Proskauer - Tax Talks

Proposed FDII Regulations under Section 250

Proskauer - Tax Talks on

On March 4, 2019, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) regarding the deduction for “foreign-derived intangible...more

Womble Bond Dickinson

US Treasury Issues Proposed Regulations on the Beneficial IRC Section 250 Corporate Tax Deduction Related to Export Sales of...

Womble Bond Dickinson on

US Treasury has now published detailed guidance on a significant US corporate tax rate benefit for any US company that conducts direct sales of property and/or services to foreign persons for foreign use. The tax rate benefit...more

Alston & Bird

FDII or Not: Section 250 FDII and GILTI Deduction Regulations Proposed

Alston & Bird on

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...more

Eversheds Sutherland (US) LLP

The Last Piece of the Puzzle - the Section 250 Proposed Regulations

Public Law 115-97 (the Tax Cuts and Jobs Act) added a new foreign income inclusion rule for global intangible low-taxed income (GILTI) under section 951A. The Tax Cuts and Jobs Act also added section 250, which permits...more

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