IRS Announces Finals Regs on FDII, GILTI Deductions

IRS finalizes guidance on deduction for foreign-derived intangible income and global intangible low-taxed income

July 9, 2020

WASHINGTON — The Internal Revenue Service issued final regulations final regulations that provide guidance on deductions for foreign-derived intangible income (FDII) and global intangible low-taxed income allowed to domestic corporations under the Internal Revenue Code.

These final regulations provide guidance on both the computation of the deductions available and the determination of FDII.

In addition, the guidance provides rules for the computation of FDII in the consolidated return context.

The guidance published today also finalizes the reporting rules requiring the filing of Form 8993, Section 250 Deduction for Foreign-Derived Intangible Income and Global Intangible Low-Taxed Income.

For more information about this and other Tax Cuts and Jobs Act provisions, visit IRS.gov/taxreform.