Final Export Tax Rules May Offer the Flexibility Companies Seek

A tax break for U.S.-based manufacturing could apply to some goods produced overseas under forthcoming final rules if tech companies get their way.

Groups representing companies like Google Inc. and Amazon.com Inc. have called for that expansion of foreign-derived intangible income (FDII) deduction rules, after the IRS released a proposed version (REG-104464-18) in March 2018 that barred certain transactions by U.S. companies from qualifying for the 50% write-off.

The Office of Information and Regulatory Affairs began reviewing the final rules Tuesday, the last major step before they can be released.

The FDII deduction, under tax ...