United States

Final FDII and GILTI regulations expected


On May 26, 2020, the Office of Information and Regulatory Affairs (OIRA) reported that final regulations under Internal Revenue Code (IRC) section 250 regarding the deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI) had been submitted for review by the U.S. Treasury Department.

The FDII and GILTI provisions were added to the IRC by the 2017 Tax Cuts and Jobs Act (TCJA). The final regulations will follow up on the proposed regulations pertaining to the deduction for FDII and GILTI, which were issued in March of 2019. The final regulations are expected to address a wide range of issues related to the deductions. To catch up on the proposed regulations, see our prior tax alert and white paper.

We will continue to monitor this area and provide updates as additional guidance is issued.


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