Maximizing the FDII Deduction for U.S. Exported Property and Services: Determining Foreign Use, Grouping Expenses, Optimizing the R&D Allocations
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE course will provide tax counsel and advisers guidance on the rules and reporting requirements for Section 250 tax deduction for foreign-derived intangible income (FDII). The panel will discuss new IRS regulations, identifying deduction-eligible income (DEI) and foreign-derived deduction-eligible income (FDDEI), the mechanics of allocation methods and calculations, and utilizing this deduction to reduce tax rates.
Outline
- Recent IRS Section 250 regulations
- Navigating FDII rules and requirements
- Identifying DEI and FDDEI
- Allocation methods and calculations
- Domestic intermediary rules
- Best practices and techniques for using Sec. 250 deduction to reduce tax rates
Benefits
The panel will review these and other critical issues:
- Recent IRS regulations for Section 250 deduction
- Understanding FDII rules and pitfalls
- Identifying DEI and FDDEI and effective tax planning
- Expenses and allocation methods and calculations
- Understanding domestic intermediary rules
- Best practices for using the Sec. 250 deduction and caveats to consider
Faculty
Pamela A. Fuller, Esq., J.D., LL.M.
Senior Counsel (Tax, M&A, International)
Tully Rinckey PLLC and Zahn Law Group
Ms. Fuller is a corporate and international tax attorney with over 20 years experience in advising a wide range of... | Read More
Ms. Fuller is a corporate and international tax attorney with over 20 years experience in advising a wide range of clients -- including private clients and companies, joint ventures, private equity funds, HNW indviduals, C-Suite executives, "start-ups," and government entities -- on transactional, investment, and supply-chain strategies to achieve optimal tax and business results. She has deep expertise in structuring cross-border M&A transactions, and advising mobile international families. Her clients hail from a multitude of industries, including the burgeoning world of decentralized finance (DeFi). Pamela is also a seasoned taxpayer advocate, with decades of experience resolving complex U.S. federal, state, and foreign tax controversies.
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Melody C. Horton, CPA
Founder
Arc Advisors
Ms. Horton has spent her career in public accounting, specializing in working with clients with international... | Read More
Ms. Horton has spent her career in public accounting, specializing in working with clients with international activities. She provides comprehensive planning and compliance services to clients with multi-state and multinational operations across a variety of industries. Ms. Horton primarily works with clients that have international operations in the manufacturing, distribution, technology, and services industries. She assists many international companies making inbound investment in the US with tax structuring and economic incentives. Ms. Horton also works with international companies to create efficient global tax strategies, maximizing their FDII benefits and minimizing the GILTI and BEAT impact. She has significant experience with income tax provisions and other ASC 740 reporting matters, international reporting requirements, foreign tax credit planning, repatriation of foreign profits, treaty analysis and voluntary disclosure filings.
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