US IRS corrects proposed international tax regulations

The US IRS today issued a correction to proposed tax regulations that implement the US’s new international tax scheme.

The corrected proposed regulations were published in the Federal Register on March 6 and provide multinational taxpayers with guidance to determine the amount of the deduction for foreign-derived intangible income and global intangible low-taxed income.

The correction is as follows:

On page 8190, in the preamble, under the heading: “2. Determination of DEI and FDDEI”, in the third column, in the 23rd line, add a sentence at the end of the paragraph to read: “Finally, the proposed regulations define financial services income by reference to section 904(d)(2)(D) and proposed § 1.904-4(e)(1)(ii).”
§ 1.250(b)-1

On page 8216, first column, the last line of paragraph (d)(3)(ii)(B)( 2)(i), the language “distributive of PRS’s gross FDDEI” is corrected to read “distributive share of PRS’s gross FDDEI”.