FDIIFood and Drink Industry Ireland (Dublin, Ireland)
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So, how do the new rules on FDII and GILTI impact the decision margins of U.S.
The effective tax rate on FDII will be 13.125% in tax years beginning after 2017 and before 2026 and 16.406% after 2025.
Mr Kelly's calls came as the FDII released its report Sharing the Harvest: The Food and Drink Sector Jobs Dividend.
TEI members are responsible for administering the tax affairs of their companies and must contend daily with provisions of the tax law relating to the operation of business enterprises, including the new FDII and GILTI regimes, along with many other aspects of the Act.
For tax years beginning after December 31, 2025, the deduction for FDII is reduced to 21.875% and the GILTI deduction is reduced to 37.5%.
FDII bosses said they would back any move to reduce business costs such as pay moderation and costs to remain competitive.
IRC Section 250 also provides a deduction to corporations for 37.5 percent of a corporation's foreign-derived intangible income, or FDII (21.875 percent beginning after December 31, 2025).
This article focuses on five key issues and strategies relating to GILTI, FDII, and the foreign tax credit and proposed regulatory guidance on these rules issued to date.
With passage of the tax reform legislation, there were many new provisions, including GILTI, FDII (foreign-derived intangible income), BEAT, and 163(j), that needed to be dealt with.