irs building_10858577

March 5, 2019

IRS Issues Proposed Regs on Deduction for Foreign-Derived Income

The Internal Revenue Service issued proposed regulations under section 250 of the Internal Revenue Code, which offers domestic corporations deductions for foreign-derived intangible income (FDII) and global intangible low-taxed income.

The Internal Revenue Service has issued proposed regulations under section 250 of the Internal Revenue Code, which offers domestic corporations deductions for foreign-derived intangible income (FDII) and global intangible low-taxed income. Section 250, as well as section 951A dealing with global intangible low-taxed income, was added by the 2017 Tax Cuts and Jobs Act (TCJA).

These proposed regulations provide guidance on both the computation of the deductions available under section 250 and determination of FDII. In addition, the proposed regulations provide rules for the computation of FDII in the consolidated return context. Proposed guidance on the computation of global intangible low-taxed income was published in the Federal Register on Oct. 10, 2018.

New reporting rules requiring the filing of Form 8993, Section 250 Deduction for Foreign-Derived Intangible Income and Global Intangible Low-Taxed Income, are also described in the proposed regulations.

Treasury and IRS welcome public comments on these proposed regulations. For details on submitting comments, see the proposed regulations.

Updates on the implementation of the TCJA can be found on the Tax Reform page of IRS.gov.

Thanks for reading CPA Practice Advisor!

Subscribe for free to get personalized daily content, newsletters, continuing education, podcasts, whitepapers and more…

Subscribe for free to get personalized daily content, newsletters, continuing education, podcasts, whitepapers and more...

Leave a Reply

Experiences 2025 – AI Search

Firm Management February 11, 2025 

Experiences 2025 – AI Search

For now, Agentic AI refers to artificial intelligence systems that operate autonomously and can perceive, reason, plan, and take action in pursuit of goals. These AI agents can interact dynamically with their environment, adapt to changes, and sometimes make decisions without direct human intervention.

Randy Johnston