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IRS Proposes Guidance on FDII, GILTI deductions

 

The U.S. Internal Revenue Service (IRS) issued guidance on determining the amount of the deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI) under Sec. 250. The’s proposed regulations also detail how taxpayers coordinate the FDII and GILTI provisions with other provisions in the Code. The proposed rules also contain amendments to regulations issued under Secs. 962 (election by individuals to be taxed at corporate tax rates), 1502 (how the deduction applies to consolidated groups), 6038 (information reporting for certain controlled foreign corporations (CFCs) and partnerships), and 6038A (information reporting for certain foreign-owned corporations). Read more at the Journal of Accountancy.