TITLE 26. INTERNAL REVENUE CODE § 250. Foreign-derived intangible income and global intangible low-taxed income, 26 USCS § 250

Summary

(a) Allowance of deduction.

(1) In general. In the case of a domestic corporation for any taxable year, there shall be allowed as a deduction an amount equal to the sum of—

(A) 37.5 percent of the foreign-derived intangible income of such domestic corporation for such taxable year, plus

(B) 50 percent of—

(i) the global intangible low-taxed income amount (if any) which is included in the gross income of such domestic corporation under section 951A [26 USCS § 951A] for such taxable year, and

(ii) the amount treated as a dividend received by such corporation under section 78 [26 USCS § 78] which is attributable to the amount described in clause (i).

(2) Limitation based on taxable income.

(A) In general. If, for any taxable year—

(i) the sum of the foreign-derived intangible income and the global intangible low-taxed income amount otherwise taken into account by the domestic corporation under paragraph (1), exceeds

(ii) the taxable income of the domestic corporation (determined without regard to this ...