On 9 July 2020, the United States (US) Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released final regulations under Internal Revenue Code (IRC)1 Section 250 (Treasury Decision 9901) for calculating the deduction allowed to a domestic corporation for its foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI). The final regulations are scheduled for publication in the Federal Register on 15 July 2020.Generally, the final Section 250 regulations reflect a structure similar to the proposed regulations released in March 2019 (see EY Global Tax Alert, US Proposed Section 250 regulations provide guidance on calculating the FDII/GILTI deduction, including qualification...