FDII Deduction Eligible Income (Section 250)

Current understanding

To be populated as evidence accumulates.

2026-08-26 — Pro Rata Share of Subpart F Income, Tested Income, or Tested Loss: cross-connection with cfc-pro-rata-share-subpart-f-tested-income: Tested income allocations under Subpart F/GILTI interact with the FDII/Section 250 deduction framework governing U.S. multinationals. (novelty: 2)
2026-08-20 — Application of Section 250(b)(3)(A)(i)(VII) to Sales or Other Dispositions of Property: IRS/Treasury proposed rules under Section 250(b)(3)(A)(i)(VII) would exclude gains from sales or other dispositions of intangible property (including patents), depreciable property, and depletable property from deduction-eligible income when computing the FDII deduction, narrowing the benefit for U.S. multinationals monetizing such assets to foreign customers. (novelty: 2)