In an article publishedin Tax Notes, A&M Taxand Managing Director Lewis J. Greenwald summarizes the final section 250 regulations recently released by Treasury to provide guidance on the deduction for foreign-derived intangible income introduced by the Tax Cuts and Jobs Act.
On March 5, 2019, the U.S. Treasury issued proposed regulations under section 250 (REG-104464-18) that provided guidance for determining the amount of the deduction for foreign-derived intangible income. Importantly, the proposed regs identified the documentation that taxpayers were required to have by the FDII filing date1 to secure their FDII deductions.
Click here to read the full article as published in Tax Notes
Mexican General Tax Rules for 2026: Changes Applicable to the Financial Sector
January 12, 2026
Overview of MFRL 2026 reforms impacting MITL, VATL, credit institutions, insurers, and capital repatriation compliance in Mexico.
New Hampshire Tax Amnesty Program Provides an Excellent, Limited Time Opportunity to Resolve Prior Period Liabilities
January 7, 2026
A limited-time New Hampshire tax amnesty program offers meaningful relief for unresolved state tax liabilities. The opportunity closes February 15, 2026.
THE NEW PILLAR TWO FRAMEWORK: UNBOXING THE SIDE-BY-SIDE PACKAGE
January 6, 2026
The OECD’s new Pillar Two Side-by-Side package introduces key safe harbours and simplifications, with implementation beginning in 2026.
OBBBA International Tax Guidance: What’s New, What’s Looming
January 6, 2026
New Treasury and IRS guidance under the OBBBA signals meaningful changes for international tax planning. Key implications are emerging now, with more to come in 2026.
