JCT overview of GILTI and FDII provisions (sections 250 and 951A)
JCT overview of GILTI and FDII provisions
The Joint Committee on Taxation (JCT) released a presentation that provides an overview of the taxation of global intangible low-taxed income (GILTI) and foreign-derived intangible income (FDII) under sections 250 and 951A. These measures were added to the Code by the tax law enacted in December 2017—Pub. L. No. 115-97—the law that is often referred to as the “Tax Cuts and Jobs Act.”
Read the JCT report: Overview of the Taxation of Global Intangible Low-Taxed Income and Foreign-Derived Intangible Income: Sections 250 and 951A (May 2019)
Proposed regulations (REG-104464-18) relating to the deduction for FDII and GILTI under section 250 were released in March 2019. Read KPMG’s report of initial impressions about the proposed regulations: TaxNewsFlash
© 2024 KPMG LLP, a Delaware limited liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
For more detail about the structure of the KPMG global organization please visit https://kpmg.com/governance.
The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.