News & Analysis as of

Internal Revenue Service Foreign Derived Intangible Income (FDII)

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
BakerHostetler

Analysis of the 2025 Federal Tax Changes Under the “One Big Beautiful Bill” Legislation

BakerHostetler on

The race to remake portions of the Internal Revenue Code (Code) and to prevent expiration of certain Tax Cuts and Jobs Act (TCJA) provisions reached completion with Legislation signed by President Trump on July 4, 2025....more

Eversheds Sutherland (US) LLP

Tax Bytes: Week of June 9, 2025

Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more

McDermott Will & Emery

[Event] Tax Symposium 2024 - May 14th - 15th, Chicago, IL

Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more

Freeman Law

[Webinar] The Freeman Law International Tax Symposium - October 20th - 21st, 9:00 am - 5:00 pm CST

Freeman Law on

Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - AN EXPERIENCE UNLIKE ANY OTHER - Find yourself on the cutting-edge of international tax law, with...more

Davies Ward Phillips & Vineberg LLP

U.S. Tax Laws: A Review of 2021 and a Look Ahead to 2022

Review of U.S. Tax Developments in 2021- Last year, we predicted that the biggest U.S. tax news in 2021 would be revenue-raising legislation that the Democrats would put forward after the election of Joe Biden as the 46th...more

Miller Nash LLP

Today in Tax: Eligibility of Electronic Services Income for FDII Deduction

Miller Nash LLP on

Brief commentary on recent cases, rulings, notices, and related federal tax guidance. Regulations open door for cloud computing, streaming, and related electronic services to be included in deduction computation....more

McDermott Will & Emery

Weekly IRS Roundup December 27 – December 31, 2021

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 27, 2021 – December 31, 2021... December 27, 2021: The IRS published a news release...more

Freeman Law

Congress Readies New Round of Tax Increases

Freeman Law on

The House Committee of Ways and Means (the “House”) has been busy the last few days. Indeed, the House continues to mark up and work through potential revenue raisers (i.e., tax increases) to help pay for recent legislative...more

Freeman Law

[Webinar] Freeman Law International Tax Symposium – General Attendee - November 18th - 19th, 8:00 am - 5:00 pm CST

Freeman Law on

Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - An Experience Unlike Any Other - Find yourself on the cutting-edge of international tax law, with...more

Pillsbury Winthrop Shaw Pittman LLP

President Biden’s “Made in America Tax Plan”

Corporate tax proposals in support of President Biden’s ambitious infrastructure plans would raise some $2 trillion over 15 years. Tighter international tax net would apply to corporations operating in low-tax...more

McDermott Will & Emery

Weekly IRS Roundup November 30 – December 4, 2020

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 30, 2020 – December 4, 2020... November 30, 2020: After releasing a pre-publication...more

McDermott Will & Emery

Weekly IRS Roundup October 26 – October 30, 2020

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 26, 2020 – October 30, 2020... October 26, 2020: The IRS released Rev. Proc. 2020-45...more

A&O Shearman

Treasury and the IRS Finalize Regulations on Withholding on the Disposition of a Partnership Interest by a Foreign Partner

A&O Shearman on

On October 7, 2020, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (IRS) finalized regulations (T.D. 9926) (the “Final Regulations”) with respect to the withholding tax imposed under section...more

McDermott Will & Emery

Weekly IRS Roundup August 31 – September 4, 2020

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 31, 2020 – September 4, 2020. Additionally, for continuing updates on the tax impact of...more

Faegre Drinker Biddle & Reath LLP

Substantiating an FDII Deduction: Certain Deal-Related Considerations Raised by New Regulations

One of the cornerstones of the current U.S. international tax system, as revised under the 2017 tax law commonly known as the Tax Cuts and Jobs Act, is the deduction provided to U.S. corporate taxpayers under section 250(b)...more

Fenwick & West LLP

The FDII Final Regulations Are Here: An Executive Summary and Observations

Fenwick & West LLP on

Treasury and the IRS released final section 250 regulations on July 9, 2020, primarily focused on the deduction for foreign-derived intangible income (FDII). The final regulations make significant revisions to the proposed...more

McDermott Will & Emery

Burdensome Documentation Requirements Modified under the Final Section 250 Regulations

McDermott Will & Emery on

The US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have issued highly anticipated guidance (the Final Regulations) regarding the substantiation requirements necessary to claim a section 250...more

McDermott Will & Emery

Government Releases Final Regulations on FDII and GILTI Deduction

McDermott Will & Emery on

On July 9, 2020, the US Department of the Treasury (Treasury) and Internal Revenue Service (IRS) released Final Regulations (Final Regulations) that provide guidance on the section 250 deduction for foreign-derived intangible...more

Alston & Bird

Talk About a Summer Beach Read – Final FDII and GILTI Regulations Released

Alston & Bird on

The IRS’s final regulations for Section 250 deductions for FDII and GILTI are here for your light summer reading. Better yet, let our International Tax Group explain it all for you....more

Fenwick & West LLP

Proposed Guidance on the Production Sourcing Rules under New Section 863(b)

Fenwick & West LLP on

The Tax Cuts and Jobs Act (TCJA) repealed the long-standing “50/50” sourcing rule for United States exporters of manufactured products. Under the new rules, which source income of a “producer” solely to the place of...more

McDermott Will & Emery

Proposed Regulations under Sections 863(b) and 865(e)(2) Revise the Rules for Sourcing Income

Proposed regulations under Sections 863(b) and 865(e)(2) implement changes by TCJA to section 863(b), the primary sourcing provision for income from the sale of inventory produced by a taxpayer without and sold within the...more

McDermott Will & Emery

Weekly IRS Roundup May 27 – May 31, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 27 – May 31, 2019. May 28, 2019: The IRS released Announcement 2019-05 listing recent...more

Proskauer - Tax Talks

Proposed FDII Regulations under Section 250

Proskauer - Tax Talks on

On March 4, 2019, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) regarding the deduction for “foreign-derived intangible...more

Alston & Bird

International Tax Regulations: The Road Ahead – Key Practitioner Concerns and Government Responses

Alston & Bird on

Our International Tax Group reflects on a few concerns that have cropped up in the wake of the Tax Cuts and Jobs Act and deciphers the government’s responses....more

McDermott Will & Emery

Weekly IRS Roundup April 8 – 12, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 8 – 12, 2019. April 8, 2019: The IRS issued a news release warning taxpayers against...more

35 Results
 / 
View per page
Page: of 2

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide