FDII Flashcards
What is FDII
Foreign-Derived Intangible Income
FDII
DII (Deemed Intangible Income) * [FDDEI (foreign derived deduction eligible Income) / Deduction eligible Income (DEI)]
DII
Deemed Intangible Income: DEI (Deduction eligible income)(excluding subF and GILTI inclusions, foreign branch income, financial services income) - DTIR (deemed tangible income return)(10% of QBAI)
DEI
(Deduction eligible income)(gross DEI excluding subF and GILTI inclusions, foreign branch income, financial services income)
DTIR
(deemed tangible income return)(10% of QBAI)
FDDEI
(foreign derived deduction eligible Income) - DEI resulting from:
- sale of prop to a foreign person for foreign use
- serv. provided to foreign persons or with respect to property not located in the US
related party restrictions!
FDDEI sales
property sold:
- to a foreign person,
- for foreign use
sale includes: lease, license, Sec 367 transfer
IP is for foreign use if location of end user is outside US
FDDEI services
services provided by the taxpayer:
- to any person not located in the US, or
- Generally with respect to property not located in the US
8990
163j
8991
BEAT
8992
GILTI
8993
250 Deduction for FDII and GILTI