TEI Submits Comments regarding FDII and GILTI Deductions

On May 6th, 2019, TEI submitted comments regarding proposed regulations implementing the new section 250 deductions for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI).  The FDII and GILTI regimes are new to the Internal Revenue Code and were enacted in 2017 via the Tax Cuts & Jobs Act.  The Institute’s comments primarily focused on the proposed regulations’ information requirements for documenting the “foreign use” of property or services eligible for the FDII deduction.  TEI’s comments were prepared under the aegises of the Institute’s U.S. International Tax Committee and Tax Reform Task Force, whose chairs are Sarah Winters and Emily Whittenburg, respectively.  Benjamin R. Shreck, TEI Tax Counsel, coordinated the production of TEI’s comments..

Download the comments here.