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Foreign Derived Intangible Income (FDII) Manufacturers

Fenwick & West LLP

Proposed Guidance on the Production Sourcing Rules under New Section 863(b)

Fenwick & West LLP on

The Tax Cuts and Jobs Act (TCJA) repealed the long-standing “50/50” sourcing rule for United States exporters of manufactured products. Under the new rules, which source income of a “producer” solely to the place of...more

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