Under the Tax Cuts and Jobs Act 2017, a domestic C corporation may claim a 37 1/2 % deduction against income derived from the sale, provision of services, and licensing to foreign persons, for foreign use, and with respect to property not located in the United States. The provision is called the foreign derived intangible income deduction or FDII. For Federal tax purposes, an effective rate of 13.125% is available. Proposed regulations issued March 5, 2019 provide critical guidance on the transactions that qualify for and  the computation of the deduction. The deduction is generally available for tax years of C corporations beginning after December 31, 2017. Thus for calendar year  domestic corporations, 2018 tax year will be the first year. To help you with this initial filing, our speaker will cover: 

  • Requirements of FDII transactions;

  • Computing the FDII deduction;

  • Application of the taxable income limitation;

  • Allocation of deductions;

  • Ordering rules for deductions limited by taxable income ;

  • Worked examples; and 

  • Tour of new Form 8993

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.

Level: Intermediate
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.

Presented By:

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: