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Foreign Derived Intangible Income: A Detailed Dive

FOREIGN DERIVED INTANGIBLE INCOME: A DETAILED DIVE

Cost Free
Presentation Length 1.5 hours

Recorded DateApril 2, 2021
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

This program will explore in detail the FDII deduction made available as part of the 2017 Tax Cuts and Jobs Act, including how it significantly buttresses arguments for multinational business enterprises to centralize activities in the United States. The program, presented by Patrick J. McCormick, will cover requirements for the deduction (who is eligible to claim the deduction and which income is deductible) and explore in detail how it can create tax savings for multinationals with foreign-sourced income.

Learning Objectives:


  • Identify taxpayers eligible for the FDII deduction

  • Determine which transactions qualify for FDII deduction benefits

  • Outline how the FDII deduction can be used in conjunction with American tax treaties to provide global tax efficiencies

  • Identify how the FDII deduction (and domestication of multinational activities) compares with GILTI inclusions/foreign incorporation

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PLEASE NOTE: ARCHIVED WEBINARS DO NOT QUALIFY FOR CPE
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Culhanemeadows

Patrick is a partner with Culhane Meadows, a national law firm with a prominent international area practice. Patrick practices exclusively in the area of international taxation. He has extensive experience handling complex tax planning, structuring, and compliance issues for foreign businesses with United States operations, United States businesses with foreign operations, and individual taxpayers with international ties. Patrick regularly works with advisors both in the United States and abroad to assist with their clients’ international tax issues.

Patrick is a prolific contributor to many international tax journals, including Tax Notes and the Journal Of International Taxation. He is an active speaker and panelist for national seminars and webinars, including regularly scheduled presentations with CPAacademy.org on various international tax topics. Patrick holds a Juris Doctorate from Vanderbilt University Law School and an LL.M. from New York University School of Law.  His bar admissions include Pennsylvania, Florida, New Jersey, and Georgia.

Each year from 2016-2019, Patrick has been recognized by Super Lawyers as a Rising Star. Finance Monthly, a United Kingdom-based publication named Patrick Estate Planning Lawyer of the Year (United States) for 2017 and 2018. Patrick and his wife reside in Phoenixville, PA.

 

About Our Presenter

Culhanemeadows
Culhane Meadows is proudly shaking up the legal marketplace by offering exceptional, yet highly-efficient and cost-effective, client services provided exclusively by partner-level attorneys with substantial experience from large law firms or in-house legal departments of respected corporations.