FDII Deduction and GILTI Rules: Claiming Section 250 Tax Incentives on Eligible Foreign Income
QBAI, Expense Allocations, Sale of Property Provisions, Deduction-Eligible Income, FDDEI Transactions, Ordering Rules
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will provide corporate tax advisers with a practical guide to the tax planning opportunities and challenges of the Section 250 FDII deduction. The panel will discuss how the final regulations impact the treatment of certain transactions to calculate deduction-eligible income and offer suggestions on tax-efficient structures to take advantage of tax savings built into the FDII deduction.
Outline
- Section 250(a) FDII deduction
- Interplay with GILTI provisions
- Rate structure
- Export incentive
- IRS proposed regulations
- FDDEI transactions
- Ordering rules
- Components of FDII computation
- Anti-abuse rules
- Deductibility of certain related-party transactions
- Impact of foreign tax credit changes to FDII
- Offshore structuring considerations to take advantage of FDII
- Impact of impending legislation
Benefits
The panel will review these and other relevant topics:
- The interplay between Section 250(a) FDII deduction and GILTI provisions
- Recent IRS regulations on calculating the FDII deduction
- Rules applicable to FDDEI transactions
- Ordering rules for computing the FDII deduction
- How to go through the multi-step process to identify, calculate, and claim the FDII deduction
- Which assets qualify as QBAI and which assets do not
- Planning opportunities around the FDII deduction
Faculty
William R. Skinner
Partner
Fenwick & West
Mr. Skinner focuses his practice on U.S. international taxation, with a particular emphasis on tax planning and... | Read More
Mr. Skinner focuses his practice on U.S. international taxation, with a particular emphasis on tax planning and international corporate transactions. He has broad experience in international tax issues for U.S. corporations, foreign corporations, and high net-worth individuals, and has represented clients across a variety of industries. He teaches international taxation as an adjunct professor in San Jose State University’s MST program, and speaks and writes frequently on international and corporate tax issues.
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Kyle Brandon
Senior Manager - International Tax
Grant Thornton
Mr. Brandon is an international tax executive focused on helping multinational businesses address their global tax... | Read More
Mr. Brandon is an international tax executive focused on helping multinational businesses address their global tax challenges. His areas of expertise include tax reform, international expansion, restructuring, planning, and cross-border transactions. He is a knowledge leader in U.S. tax export incentives. He previously worked for a private company specializing in international trade, specifically with India and China. He has been involved with the many aspects of international taxes, including tax reform, international structuring and reorganizations, repatriation, GILTI, FDII, BEAT, foreign tax credit planning, value-added tax, and the related international tax compliance. He spent time working in transfer pricing, helping multinational companies manage their cross-border transactions and related transfer pricing documentation requirements. He is a leader of Grant Thornton’s U.S. export tax incentives group, which includes planning and implementing U.S. tax export opportunities for qualifying companies.
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