IRS CCA: Military Consulting Services Provided to US Government Outside the US Is Foreign-Derived Deduction Eligible Income (IRC §250)

Services provided by a military consulting firm to the US government (including any political subdivision, agency, or instrumentality thereof) where the recipient is not located within the US, may qualify as services provided to “any person…not located within the United States” for purposes of the foreign-derived deduction eligible income under I.R.C. §250(b)(4)(B), the Chief Counsel’s Office advised. Domestic corporation (D), hired by the US DoD to provide general consulting services, provides services to employees of the US DoD located on a military base in country X. D’s consulting services qualify as general services provided to a business recipient because the ...