IRS proposes regs on deduction for foreign intangible income

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The IRS has proposed regulations that offer domestic corporations deductions for foreign-derived intangible income and global intangible low-taxed income, both added by the Tax Cuts and Jobs Act.

The regs provide guidance on computation of deductions under Sec. 250 and determination of FDII, and provide rules for the computation of FDII in the consolidated return context.

New reporting rules requiring the filing of Form 8993, “Section 250 Deduction for Foreign-Derived Intangible Income and Global Intangible Low-Taxed Income,” are also part of the proposed regs.

The Treasury and the IRS are currently accepting public comments on the proposed regs; they can be submitted electronically at, or mailed to: CC:PA:LPD:PR (REG-104464-18), Room 5203, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044.

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