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International Aspects of Tax Cuts and Jobs Act 2017 – Part II – Advising Clients Serving Foreign markets from a U.S. Base
Taxation Law Section
Credit(s):
1.5 Legal Specialization in Taxation Law
1.5 Participatory MCLE Credits
TCAJA introduced two alternative tax regimes available to U.S. based businesses serving foreign markets. The two regimes are the Foreign Derived Intangible Income (FDII) available only to domestic C corporations and Qualified Business Income (QBI) Deduction (§199A). FDII offered a 13.125% effective corporate tax for C corporations. QBI offers an effective rate of 29.6% to individuals and noncorporate owners of passthrough business entities. These two essentially alternative and mutually exclusive concepts need to be considered by practitioners advising clients with foreign customers. Both provisions with emphasis on FDII will be illustrated with worked examples reflecting the latest available guidance.
1.5 Legal Specialization in Taxation Law
1.5 Participatory MCLE Credits
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