Page 436 - Large Business IRS Training Guides

FDII - Example 7 - Consumer Hypothetical

sold to a consumer is for a foreign use, and whether the
Determining if property
qualifies for the 250 deduction with respect to FDII, can depend on
sale potentially
of factors.
a variety

Assume a U.S. corporation sells
property to a foreign person that is a consumer.
Consider
how the answer on foreign use will change if the consumer(s) is/are:

• delivered the property
abroad, and the consumer uses the property to operate a
business abroad,

abroad, and the consumer uses the property to operate a
• delivered the property

business both abroad and in the U.S.,
• individuals
or business customers who are delivered the property both abroad
and in the U.S.

What if
the sale consists of intangible property delivered
online (for
example, to a device)?

67