"Tax-Favored" Foreign Income: Planning Pointers and Traps
An Overview of the FDII and GILTI Deductions
The Tax Cuts and Jobs Act reduces the corporate income tax rates of C corporations to 21 percent. The TCJA further reduces the C corporation income arising from tax-favored foreign income by means of two deductions - the Foreign-Derived Intangible Income deduction and the Global Intangible Low-Taxed Income deduction. This white paper reviews these two deductions and explains how the FDII and GILTI deductions are computed. This material also discusses how to defend the FDII and GILTI deductions in tax audits.
Founder of M. Robinson & Company, P.C., Tax Law Specialists, a tax firm located in Boston's financial district since 2005
Experienced tax lawyer and certified public accountant with more than 30 years of tax law practice
Focuses his practice on federal, international, and multistate taxation of businesses and individuals; this includes tax planning for the sale of businesses and resolving highly complex tax issues under the Offshore Voluntary Disclosure Program
Frequent speaker in front of local and national audiences on topics ranging from family-oriented tax planning to the tax and legal issues facing retirees living overseas
Written numerous publications including “State Voluntary Disclosure Programs: An Overview,” Tax Analysts, State Tax Notes (January 18, 2016) and “Use State Voluntary Disclosure When Complying with Expanded Nexus,” Tax Analysts, State Tax Notes (February 29, 2016)
Member of the American Academy of Attorney-Certified Public Accountants (president, New England Chapter), Boston Bar Association (Federal Tax Committee), and Massachusetts Society of Certified Public Accountants (State and Federal Tax Committees)
J.D. and LL.M degrees, Boston University School of Law; B.S. degree, Babson College
Can be contacted at 617-428-0055, [email protected], on LinkedIn®: https://www.linkedin.com/in/morrisrobinson, or on Twitter®: @MRobinsonCo
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