Page 393 - Large Business IRS Training Guides

Exclusions
in Computing FDII

eligible for the IRC 250 deduction determined
• Income NOT

(exclusions):
by reference to FDII

• Income from CFC
dividends

IRC 951(a)(1) (subpart F and section
• Income under
956 income)

951A (GILTI)
• Income under IRC

• Foreign branch income (now a separate category of

income for purposes
of the IRC 904(a) FTC

computation)

• Financial
services income

• Domestic oil and gas extraction income

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