The U.S. IRS has released an international practice unit on IRC Section 250 Deduction: Foreign-Derived Intangible Income (FDII). The general overview of the practice unit includes the following: The Tax Cuts and Jobs Act enacted section 250, which provides for a deduction with respect to Global Intangible Low-Taxed Income (GILTI) and Foreign-Derived Intangible Income (FDII). The deduction is only available to domestic corporations (except that the GILTI deduction is also available to individuals that make a section 962 election). The section 250 deduction helps neutralize the role that tax considerations play when a domestic corporation chooses the location of intangible...