Page 409 - Large Business IRS Training Guides

Special Rules for Documenting

Qualifying Transactions
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• Exceptions
to the documentation requirements include:
business exception for general property and general services:
• Small
Taxpayers
with gross receipts less than $10 million in a prior year can
rely on a recipient’s address in deciding if a transaction qualifies
simply
etc.).
(foreign person, foreign use,
• Small transaction exception for general property and general services:

Taxpayers with gross receipts less than $5,000 in a taxable year from a

single recipient can simply rely on the recipient’s address to determine if a

transaction qualifies.
• Anti-abuse provision: If a taxpayer knows, or has reason to know, that a
transaction would otherwise generate FDDEI, but the taxpayer fails to

satisfy the documentation requirements, such transaction will nonetheless
be treated as FDDEI if doing so reduces FDDEI.

• Transition rule – the formal documentation requirements are proposed

to be effective for taxable years beginning after March 4, 2019 - prior to

this any reasonable documentation maintained in the ordinary course

of a taxpayer’s business may be used to establish that a transaction

produces FDDEI.

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