EYUS final GILTI/FDII regulations under Section 250 include guidance on Section 962 elections, pass-through FDII reporting
|Tax Alerts, National/Federal Taxation, L ...|United States
The final regulations on the Internal Revenue Code1 Section 250 deduction for global intangible low-taxed income (GILTI) and foreign-derived intangible income (FDII) (TD 9901) (the Final Regulations) significantly affect individuals and certain trusts that hold direct and indirect interests in controlled foreign corporations (CFCs) and make elections under Section 962. Section 962 e…
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