Exploring Section 250: Foreign Derived Intangible Income (FDII)

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:

1. Identify the requirements to obtain the FDII deduction
2. Review the type of income subject to deduction under the FDII rules
3. Compare the FDII deduction with alternatives (i.e. foreign incorporation/GILTI inclusion)
4. Explore non-tax factors which often lead multinational to favor American incorporation