Formulas and Figures
Deemed intangible income times (FDDEI/DEI)
What is Foreign-derived intangible income (FDII)?
DTIR
What is deemed tangible income return?
Definition of a FDDEI sale.
What is a sale of ‘general property’ or ‘intangible property’ to a foreign person for a foreign use.
In May, this entity submitted a letter to Treasury and the IRS suggesting that FDII may violate international trade law.
What is the European Union ("EU")?
This actor plays the main character in the film 'The Accountant'.
Who is Ben Affleck?
Qualified Business Asset Investment times 10%
What is the Deemed Tangible Income Return?
DEI
What is deduction eligible income?
Effective date of proposed regulations.
What are the taxable years ending on or after March 6, 2019?
Jeff Becker has this many children.
What is the number three?
Is famous for saying, "So just call me bond, municipal bond."
Who is Ben Wyatt from Parks and Rec?
The current FDII Deduction percentage.
What is 37.5%?
Property sold by a related party or used by a related party in connection with property sold or the provision of services to another person who is an unrelated party who is not a US person.
What is Foreign use property?
A service that is a transportation service cannot also be _____ .
What is a property service?
A seller is a ‘small business’ or engages in ‘small transactions’ when it establishes the recipient’s status as a foreign person by showing _____
What is the recipient’s shipping address is outside the United States?
This accountant had a cat named Sprinkles.
Who is Angela Martin from The Office?
The formula for Deemed intangible income
What is Deduction eligible income (DEI) minus Deemed tangible income return (DTIR)?
The FDII deduction is available to this type of taxpayer.
What are C Corporations that are not RICs or REITs?
This must be met in order for a taxpayer's sales to foreign parties to qualify as FDDEI sales.
What is foreign use?
DEI is the excess of gross income of domestic corporations, with some income excluded. Of the three options below - this is not specifically excluded as part the DEI calculation.
DEI is the excess of gross income of a domestic corporation excluding:
A) Subpart F inclusions
B) GILTI
C) any financial services income
D) They are all excluded.
What is D?
Will Ferrell plays a forensic accountant in this 2010 film.
What is 'The Other Guys'?
The allowable FDII deduction percentage for tax years beginning after December 31, 2025.
What is 21.875%?
What are the differences between QBAI for purposes of GILTI and FDII?
1. QBAI for purposes of FDII is not reduced for interest expense.
2. For purposes of FDII, it does not matter whether QBAI generates FDDEI.
The ordering rules for calculating the Sec. 250 deduction, the Sec. 163(j) limitation and the NOL are found under this proposed regulation.
What is Prop. Reg. Sec. 1.250(a)-1?
Spell Liz from Transfer Pricing's last name without cheating.
What is Y-A-N-N-A-K-A-K-I-S?
In Parks and Rec, Ben Wyatt repeatedly turns down job offers from this accounting firm.
What is Tilton & Radomski Accounting.