Section 951A and Deduction Eligible Income Allocation
Current understanding
To be populated as evidence accumulates.
Evidence log
- 2026-09-11 — Allocation and Apportionment of Deductions to Foreign Source Section 951A Category Income and Deduction Eligible Income: IRS/Treasury proposed rule sets methodology for allocating and apportioning deductions to foreign-source Section 951A category (GILTI) income and to Deduction Eligible Income (FDII), affecting multinationals’ foreign tax credit limitation and Section 250 deduction calculations. (novelty: 2)
Open questions
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Contributing findings
Allocation and Apportionment of Deductions to Foreign Source Section 951A Category Income and Deduction Eligible Income
11-sep-2026
novelty 2
per-area 2
introduces