Читать книгу International Taxation - Adnan Islam - Страница 23

 As an incentive to keep intangible assets, functions, and activity inside and originating in the United States and also encourage U.S. export activity, a U.S. C corporation is allowed to deduct 37.5% of its foreign-derived intangible income (FDII) for taxable years beginning after December 31, 2017, and before January 1, 2026. For taxable years beginning after December 31, 2026, the FDII deduction is reduced to 21.875.

 FDII of a U.S. corporation is generally the excess of its gross income over deductions properly allocable to such income, to the extent such income is derived in connection with the sale of property to a non-U.S. person for a foreign use, or services provided to any person (or with respect to property located outside the United States) located outside the United States.

 The objective or hope was for the U.S. Treasury to impose an ETR of 13.125% on qualified FDII of C corporations. However, tax rate modeling and detailed tax computations have shown that such an ETR will not always be the result. At times, it can be higher.Compare the existing IC-DISC regime that benefits non C corps, such as individuals, S corps, partnerships, and LLCs that primarily export tangible property of at least 50% U.S. component or origin.