I.R.C. Section 250: Proposed and Final Regulations Explained

Summary

This practice note provides an overview of I.R.C. Section 250 and the changes made by the Tax Cuts and Jobs Act. It also discusses the proposed and final regulations that provide the rules pertaining to deductions under the global intangible low-taxed income (GILTI) and the foreign derived intangible income (FDII) regimes, computation of FDII, partnership qualified business asset income (QBAI), the election by individuals to be subject to tax at corporate rates, and tax reporting.