Latest Articles

On March 4, 2019 in REG-104464-18, the government released proposed FDII regulations under section 250. The rules provide important computational and definitional provisions in applying section 250. The much-awaited proposed rule-making also contains rules coordinating the deduction for FDII with the  deduction also allowed under section 250 with respect to global intangible low-taxed income (GILTI). Under section 14202(a) of the Tax Cuts and Jobs Act, P.L. 115-97 (2017)(TCJA), section 250 allows for a deduction for a…