Elizabeth Stevens Moderates Panel on FDII at AICPA & CIMA U.S. Tax Update Conference

Section 250, which provides deductions for GILTI and FDII, was intended to make U.S. taxpayer’s neutral as to whether foreign derived intangible income is earned in the U.S. or outside the U.S.  Proposed regulations under section 250 provide detailed information and documentation rules for purposes of determining a taxpayer’s foreign derived intangible income.  This session will discuss the requirements of the proposed regulations and will explore, through case studies, the practical application of the proposed regulations, focusing on the different requirements for various sales and services transactions.