Page 433 - Large Business IRS Training Guides

FDII - Example 4 - Retailer Hypothetical

property sold to a retailer is for a foreign use, and whether
Determining if
qualifies for the 250 deduction with respect to FDII, can
the sale potentially

depend on a variety
of factors.

Assume a U.S.
corporation sells property to a foreign person that operates

stores.

retail Consider how the answer on foreign use will change if the

retailer
operates:
physical stores abroad,
• only

• physical
stores in the U.S. and abroad,

• physical
stores abroad, and also sells products online to customers in
and abroad.
the U.S.

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