September 15, 2020
The Relaxed FDII Documentation and Transition Rules Don’t Stop Giving
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
