New Section 250: Foreign Derived Intangible Income (FDII)


New Section 250: Foreign Derived Intangible Income (FDII)


Recorded on April 7, 2019 - No CE Credits

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.

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