The U.S. IRS has released an international practice unit on IRC Section 250 Deduction: Foreign-Derived Intangible Income (FDII). The general overview of the practice unit includes the following:
The Tax Cuts and Jobs Act enacted section 250, which provides for a deduction with respect to Global Intangible Low-Taxed Income (GILTI) and Foreign-Derived Intangible Income (FDII). The deduction is only available to domestic corporations (except that the GILTI deduction is also available to indivi…