Page 384 - Large Business IRS Training Guides

FDII
in a Nutshell

• The FDII computations are complex, but the

are simple…
questions underlying FDII

amount of intangible income is the domestic
• What
corporation deemed to produce?

-and­

• What is
the foreign-derived ratio of that deemed

intangible income?

Note: foreign-derived ≠
foreign source

as sourcing)
(not the same concept

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