Page 155 - International Taxation IRS Training Guides

TCJA
International Changes (Cont'd)

 Reduced rate on income derived from
foreign activities

a US corporation, known as Foreign-Derived
of

Intangible Income or
FDII

 Minimum
tax on deductible payments made by US

corporations to related foreign persons,
known as Base
BEAT
Erosion and Anti-Abuse Tax or

 Disallowance of deductions
related to hybrid

instruments and transactions

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