IRS T.D.: Deduction for Foreign-Derived Intangible Income, Global Intangible Low-Taxed Income Rules Corrected (IRC §250)

Corrections to final regulations that provide guidance regarding the deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI) and for coordinating the deduction for FDII and GILTI with other provisions in the Internal Revenue Code, the IRS released November 2. The primary corrections, affecting the Preamble, reflect a change to the applicability date and the interplay between tax code Section 250 and Section 861, the IRS stated. The corrections are effective November 2, 2020. [T.D. 9901, RIN 1545-BO55, 85 Fed. Reg. __ (Nov. 3, 2020)]

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