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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Law

Date & Time
  • event Date

    Wednesday, January 6, 2021

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$347.00
CLE
CPE
ALL

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.

Faculty

Pamela A. Fuller
Senior Counsel (Tax, M&A, International)
Tully Rinckey PLLC and Zahn Law Group, LLP

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
Founder
Arc Advisors

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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Description

Section 250 deduction for FDII provides tax incentives to U.S. exporters. It allows domestic corporations to deduct 50 percent on their GILTI inclusion and associated Section 78 gross-up amount and 37.5 percent on their FDII. Tax counsel and advisers must consider using these tax incentives in business structures and tax planning techniques for U.S. exporters.

The final regulations change documentation standards and explain what fulfills the substantiation requirements. They also confirm a taxpayer's ability to claim the Section 250 deduction concerning its GILTI inclusion and associated Section 78 gross-up amount when an individual taxpayer elects, under Section 962, to be taxed as a corporation.

The regulations modify how to determine foreign persons and foreign branch income and whether sales of general property through related parties and intangible property sales generate FDDEI. There are revisions on the sale of digital property and the provision of certain services.

However, computing the deduction is somewhat complicated and requires the determination of DEI, DII (deduction-intangible income), DTIR (deemed tangible income return), and FDDEI. Understanding the calculation components and how to maximize the Section 250 deduction is critical for tax counsel and advisers working with companies doing business abroad.

Listen as our panel of tax attorneys and advisers provides an in-depth analysis of the final Section 250 regulations, identifying DEI and FDDEI, the mechanics of allocations and calculations, and best practices in utilizing the deduction to minimize taxes.

Outline

  1. Recent IRS Section 250 regulations
  2. Navigating FDII rules and requirements
  3. Identifying DEI and FDDEI
  4. Allocation methods and calculations
  5. Domestic intermediary rules
  6. 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

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify specific changes made to the proposed Section 250 regulations
  • Determine ways to satisfy documentation requirements
  • Decide what is considered a digital sale
  • Ascertain when a business may benefit from applying the final regulations retroactively

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of pass-through taxation, including taxation of partnerships, S corporations and sole proprietorships, qualified business income, net operating losses and loss limitations; familiarity with net operating loss carry-backs, carry-forwards and carried interests.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).