Page 197 - International Taxation IRS Training Guides

FDII Deduction

calculation applies a formulaic approach to
 FDII

determine deduction amount

 FDII
amount is generally the amount of net income
return” attributable to (1) property sold
above a “normal

services provided to a person,
to foreign persons or (2)

or with respect to property, outside the US

• Normal return determined based on 10% of
QBAI similar to
determination under GILTI

• Special rules for
related party sales and services

52