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What C Corporations Need to Know About the FDII Deduction

Posted by Lynn Eller in Tax: Business, Tax: International.

Foreign-derived intangible income (FDII) is generated when a C Corporation serves foreign markets. This includes the sale of property, licensing intangible property, as well as providing services to an entity located outside of the U.S.

What Is the FDII Deduction?

The Tax Cuts and Jobs Act (TCJA) introduced a new federal income tax deduction that domestic C Corporations must consider for tax years beginning after 2017.

A domestic C corporation can claim a 37.5% deduction against its FDII. The deduction becomes 21.875% for tax years beginning after 2025.

How to Identify Qualifying Income for the FDII Deduction

The process to determine eligibility, identify qualifying income, and properly calculate FDII tax benefits can be complicated. A proactive tax planning strategy that considers the C Corporation’s structure will help to maximize potential tax savings.

To ensure compliance with tax law, C Corporations must understand items that are excluded from FDII and deduct expenses against foreign sales and services income.

C Corp Scenarios Requiring Special Consideration

Special strategic consideration should be given to the following situations:

Scenario #1: The C Corporation has both FDII and Global Intangible Low Taxed Income (GILTI)

How PBMares Can Help: We help clients perform modeling computations to understand and document the interaction of these two tax-related scenarios, and subsequently design a strategy that maximizes the FDII benefit while minimizing the impact on GILTI.

Scenario #2: The C Corporation operates offices outside the U.S. that qualify as a “foreign branch” of business

How PBMares Can Help: C Corporations can strategically structure supply chains to generate legitimate income from sales and services that are FDII-eligible.

Learn More

Learn more about how PBMares can help leverage this tax-saving opportunity by developing strategies to maximize benefits and identifying FDII-eligible sales and services. Contact us today.


Be sure to consult with your financial or tax advisor on this topic as individual situations may vary. The information contained in this article or webinar, and any related materials, are for informational purposes only, and cannot be relied upon for legal, financial, tax, accounting, or other professional services advice. The content is provided on an “as is” basis and PBMares makes no representations or warranties about the accuracy or sustainability of any information for your purposes. For any specific questions you may have, please contact us.

This content is accurate at the time of publication. Always ensure you are reviewing the most recent information available. Contact your tax or financial advisor if you need clarification.

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About the Author

Lynn Eller
Lynn Eller

CPA, APCIT, PFS
Partner, International Tax Team
Fairfax

Lynn’s knowledge of owner-managed businesses’ tax needs and hands-on approach to her work makes her a valued asset to her clients in a variety of industries, including professional services, real estate, healthcare, and manufacturing.

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