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Taxpayer-friendly final regulations: FDII & GILTI high-tax exception

Presented By:
Ben Cote Randall Janiczek Lisa Roelofs Steve Schnepel
Wednesday, Sept. 2, 2020
View on-demand
Recent final regulation packages for FDII and GILTI provide taxpayer-friendly changes. Our international tax experts walk through these changes and help taxpayers understand how to maximize their potential.
Man sitting in a dark room looking at his laptop

Recent final regulation packages for FDII and GILTI provide taxpayer-friendly changes that taxpayers may implement into 2019 tax returns, or in some cases, amended 2018 returns. The FDII regulations provide significant relaxation of the controversial documentation rules, while the GILTI regulations allow for a GILTI exclusion for the foreign corporations subject to a high rate of foreign tax. During this webinar, our experts will discuss the items taxpayers should understand about these changes in order to maximize their potential to realize permanent tax savings on 2019 and 2018 amended returns.

Learning objectives:

  • Understand the new, taxpayer-friendly documentation rules to substantiate your FDII calculation.
  • Determine whether to elect the final Section 250 regulations for 2019 FDII calculations.
  • Evaluate whether the new GILTI high-tax exception can reduce 2019 taxes or reporting complexity.
  • Identify opportunities to recover net operating losses or apply for refunds on 2018 amended tax returns using the GILTI high-tax exception.


  • Lisa Roelofs, senior manager, international tax


  • Ben Cote, senior manager, international tax
  • Randall Janiczek, partner, international tax
  • Steve Schnepel, partner, international tax

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