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U.S. IRS Releases Updated Practice Unit on Deduction for Foreign-Derived Intangible Income

01 November 2024

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Approved Changes

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United States

The U.S. IRS has released an updated practice unit, IRC Section 250 Deduction: Foreign-Derived Intangible Income (FDII). The practice unit was updated to remove references to resources that are no longer available and supersedes the 28 June 2021 practice unit with the same title. 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...