TAX 9869 Lecture 41: 41

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17 Jul 2020
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Introduction to fdii foreign-derived intangible income : starting in the 2018 tax year, new 250 allows a domestic corporation servicing foreign markets to deduct 37. 50% of its calculated fdii. At the new 21% corporate tax rate, this results in an effective tax rate of 13. 125% on a corporation"s foreign-derived income. For tax years beginning after december 31, 2025, the allocable deduction is reduced to. The fdii deduction is limited to taxable income (after application of net operation loss carryovers) and such limitation works in conjunction with the gilti rules. If a taxpayer"s fdii plus gilti income exceeds the taxpayer"s taxable income for the taxable year determined without regard to the 250 deduction, the excess is allocated pro-rata to reduce the taxpayer"s. Fdii and gilti income for the purpose of 250. Currently, regulated investment companies, real estate investment trusts, s corporations,

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