On Demand
Audio
Exploring Section 250: Foreign Derived Intangible Income (FDII)
Produced on December 07, 2020
Course Information
Course Description
This program will explore in detail the FDII deduction made available as part of the 2017 Tax Cuts and Jobs Act, and how it significantly buttresses arguments for multinational business enterprises to centralize activities in the United States. The program, presented by Patrick J. McCormick, will cover requirements for the deduction (who is eligible to claim the deduction, and which income is deductible), exploring in detail how it can create tax savings for multinationals with foreign-sourced income. The course will also cover how American incorporation in light of the FDII deduction can create the lowest global tax bill.
This program will benefit tax attorneys and attorneys with multinational clients.
Learning Objectives:
- Identify the requirements to obtain the FDII deduction
- Review the type of income subject to deduction under the FDII rules
- Compare the FDII deduction with alternatives (i.e. foreign incorporation/GILTI inclusion)
- Explore non-tax factors which often lead multinational to favor American incorporation
Credit Information
Faculty
Patrick J. McCormick
Culhane Meadows Haughian & Walsh PLLC
Patrick is a partner with Culhane Meadows, and practices exclusively in the area of international taxation. Patrick works both with international-domiciled individuals and businesses entering the United States market and United States taxpayers with international connections. His diverse international tax background –previously having been a partner both at a law firm and an accounting firm – gives him a full understanding of the tax complexities posed by multinational connections, and his familiarity with the minutia of international tax law allows him to optimize tax results for his clients. Patrick holds a Juris Doctorate from Vanderbilt University Law School and a LL.M. from New York University School of Law.
Patrick assists individual clients in areas including residency planning, asset ownership structuring, and minimization of global income tax bills for foreign-sourced income items. For businesses, Patrick’s representation covers an extensive scope of multinational transactions, including classification of foreign entities, options for structuring multinational transactions, and minimization of American anti-deferral tax mechanisms. Patrick assists his clients in all areas where their international ties are a relevant factor.
Bar Admissions:
Pennsylvania, New Jersey, Florida, Georgia
Reviews
Good Stuff!!
I’ll admit, he talked very fast but he had a lot of topics to get through. He was extremely knowledgeable and thorough.
Excellent