BTAX OnPoint: Rules for Tax Deduction on Exports Finalized

July 10, 2020, 7:00 PM

The IRS and Treasury have finalized rules for a tax break on exported goods and services that offers more flexibility on documentation requirements for obtaining it.

The final regulations (T.D. 9901), under Section 250 for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI), address numerous issues related to a deduction for domestic corporations, including requirements to prove eligibility and computational and ordering rules. Section 250, established under the 2017 tax law, is meant to encourage manufacturing in the U.S.

The final regulations generally adopt the structure of proposed regulations (REG-104464-18) released in March ...

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