New Section 250: Foreign Derived Intangible Income (FDII)
Thursday, January 10, 2019 - Earn 1.5 CPE/CLE Credits
Live Webinar United States Time Zones:
1:00 PM – 2:30 PM EDT / 12:00 PM – 1:30 PM CDT / 10:00 AM – 11:30 AM PDT
This webinar is presented at an intermediate level. The webinar is designed for tax professionals working as outside international tax advisors and for tax and financial executives and staff employed by domestic corporations with current or future foreign operations.
Under the new tax law, Section 250 provides a deduction for excess returns earned directly by a U.S. corporation from foreign sales or services. The FDII amount is the amount of the corporation’s “deemed intangible income” attributable to sales of property to foreign persons for use outside the U.S. or the performance of services for foreign persons or with respect to property outside the U.S. Deemed intangible income is its gross income that is not attributable to a CFC, foreign branch, or domestic oil and gas income reduced by related deductions11 and an amount equal to 10% of the aggregate adjusted bases of its U.S. depreciable assets.
The Section 250 deduction to U.S. corporations is 37.5% of FDII inclusion amounts, creating an effective tax rate on such income of 13.125%.13 These rates apply to tax years 2018 through 2025. Beginning in 2026, this deduction is reduced to 21.875% with an effective tax rate of 16.406%.14 This deduction is not available for S corporations, RICs, or REITs.
Delivery Method: Group-Internet Based Live
Recommended CPE/CLE Credit: 1.5 Credit
Field of Study: Taxes
Prerequisites: An introductory course on international taxes and a working knowledge of international transactions
Advance Preparations: None
Who Should Attend: This webinar is for CPAs, tax executives, accountants, tax attorneys and financial executives.
William K. Norman is a Partner in the law firm of Ord & Norman in Los Angeles, California and is a Coordinator of its Private Client and International Business Transactions Departments. He is also a member of the firm’s Tax Litigation and Controversy Group. He is a Certified Specialist in Taxation Law. In his practice, he focuses on the counseling of clients in cross border business transactions, cross border real estate investment structures, personal wealth planning for the multinational family, offshore voluntary disclosures, expatriation's of U.S. citizens and green card holders, use of trusts by multinational families, and representation of taxpayers before the IRS and the Tax Court. Mr. Norman received an A.B. degree in economics from the University of California at Berkeley, a J.D. degree from the University of California and an LL.M. (in taxation) degree from New York University School of Law. He is a senior adjunct professor in the Graduate School of Taxation, Golden Gate University. He is immediate past chair of STEP-LA Branch. He has appeared as a speaker and seminar leader at the USC Tax Institute and the New York University Tax Institute. In June of 2008, the Taxation Section of the Los Angeles County Bar Association presented the Dana Latham Award to him in recognition of his outstanding contributions to the field of taxation. For more information: