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May 24, 2019

An Overview of the Proposed Regs on the FDII and GILTI Deduction

In March, the IRS issued proposed regulations that cover determining the amount of the deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI). The regs also coordinate the FDII and GILTI deduction with other tax provisions. Here’s an overview.

Background

The Tax Cuts and Jobs Act (TCJA) established a “participation exemption system” under which certain earnings of a foreign corporation can be repatriated to a corporate U.S. shareholder without U.S. tax. (This occurs under Internal Revenue Code Section 245A.) (more…)

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Categories: International Business Issues, Spring 2019
Tags: Domestic Corporation, FDII, GILTI, international tax,

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