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Foreign-Derived Intangible Income Guidance Addresses Many Open Questions

The law known as the Tax Cuts and Jobs Act of 2017 (TCJA) made many significant changes to the international tax regime. One important change is Sec. 250, which was enacted by Section 14202(a) of the TCJA, and generally provides a domestic C corporation (1) a deduction for its foreign-derived intangible income (FDII) for the tax year, and (2) a deduction for its Sec. 951A global intangible low-taxed income ...

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