Page 412 - Large Business IRS Training Guides

Computing FDII and the 250 deduction

STEP 1

– Determine Deduction Eligible Income (DEI)
STEP 1

• A domestic corporation’s deduction eligible income for a taxable year is

equal to the corporation’s gross DEI reduced (but not below zero) by

deductions allocated and apportioned to both gross FDDEI, and gross

DEI that is not gross FDDEI.

• A domestic corporation’s gross DEI does not include the following items of
income:
gross
amount included in gross income under IRC 951(a)(1) (including tax
• any
gross-up),
gross income inclusion under IRC 951A (GILTI including tax gross-up),
• any
financial services income,
• any
dividend received from a corporation which is a controlled foreign
• any
the domestic corporation,
corporation of
domestic oil and gas extraction income, and
• any
foreign branch category income, not including any income treated as
• any
income under the look-through rules.
foreign branch category

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