Treasury releases final Section 250 regulations

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July 2020

Overview

Today, the Federal Register released the final regulations for the FDII and GILTI deduction under Section 250. Section 250 was enacted under the 2017 tax reform act and set forth a deduction for domestic corporations equal to the sum of 37.5 percent of their foreign-derived intangible income and 50 percent of their global intangible low-taxed income and section 78 amount, up to a limit based on taxable income. Section 250 also introduced rules for determining FDII. The final regulations are effective 60 days from the date of publication in the Federal Register (scheduled for publication in the Federal Register on July 15). Generally, the final regulations are applicable for taxable years beginning on or after January 1, 2021 (with some exceptions). However, taxpayers may apply the final regulations for taxable years beginning on or after January 1, 2018, provided they apply the regulations in their entirety (with some exceptions).

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