Foreign-derived intangible income: Issues and practical strategies

The foreign-derived intangible income (FDII) deduction provides a planning tool for U.S. C corporations that export goods to, or perform services for, foreign persons. In a 2018 Tax Insider, I wrote about FDII providing tax rates as low as 13.125% to qualifying taxpayers and how the benefit itself is calculated. Since that time, various issues and strategies have evolved around FDII where, despite proposed and final regulations, there has been very little primary or interpretive guidance. The purpose of this