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Self-Study Courses

Final FDII (Section 250) Regulations (Currently Unavailable)

2 CPE Credits $31.00/credit hour
4.8 (10 ratings)
This course will cover the new export tax incentive and planning opportunity only for C corporations that derive foreign revenue by serving foreign markets under Section 250, enacted by the Tax Cuts and Jobs Act (TCJA). U.S. tax professionals who wish to learn about: a summary and relevant overview of FDII; the Section 250, final FDII July 2020 regulations; and practice considerations for utilizing FDII tax deduction should take this course.

Publication Date: October 2020

Designed For
Experienced tax staff through tax director level interested in or already practicing international taxation.

Topics Covered

  • Foreign Derived Intangible Income
  • FDII (misnomer), Section 250
  • Export tax incentive
  • C corporations only
  • Final FDII regulations July 2020 (TD 9901)
  • Computing FDII, QBAI, Form 8993
  • Substantial and Documentation
  • FDDEI Sales: Final FDII regulations July 2020 TD 9901
  • FDDEI Services: Final FDII regulations July 2020 TD 9901
  • FDDEI Related Party Transactions

Learning Objectives

  • Identify the Section 250 FDII tax fundamental points created by the TCJA
  • Recognize the updates and differences to the Section 250 FDII July 2020 regulations
  • Recognize planning opportunities and practical considerations for the Section 250 FDII tax incentive
  • Identify steps in the FDII computation
  • Recognize FDDEI categories

Level
Intermediate

Instructional Method
Self-Study

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
Read IRC Section 250 and Form 8993 Instructions.

Advance Preparation
None

Instructor

Adnan Islam

Adnan Islam, Esq., CPA, is a partner with Friedman LLP, co-chair of the International Tax Services group, and a leader of its Blockchain/Digital Asset Transactions group. He has nearly 17 years of public accounting experience as a licensed tax attorney and CPA. Adnan has served an array of industries and clients ranging from startups to publicly traded companies including Avon, MeadWestVaco, Honeywell, Verizon, Agilent, SunGard, Booz Allen, IDT, SunGard, AMEX, OUAI, IBISWorld, Conair, Grayscale, DCG, and various blockchain and crypto (digital asset) companies, exchanges, and private equity and hedge funds. Adnan specializes in cross-border strategies, comprehensive inbound tax services, global information reporting, and structuring for crypto funds, companies, and exchanges.

As an industry thought leader, Adnan has lectured on international tax at TEI events, AICPA seminars and served as an adjunct professor for Golden Gate University Master’s in Tax curriculum. Adnan’s expertise includes advising clients at all stages of business and restructuring, with respect to FDII, GILTI, 245A DRD, subpart F, PFICs, and other issues. Additionally, Adnan empowers his clients’ decision-making and improves their supply chain and operational efficiency, including the use of holding companies, treaty country networks, and affirmative tax planning through comparative rate modeling.

Adnan is a licensed attorney admitted to practice law in New Jersey, DC, and California and a Certified Public Accountant (NY & CA). He holds a Juris Doctor (J.D.) and an M.B.A. from Rutgers University; an LL.M. in Taxation from the New York University School of Law; a blockchain business certificate from MIT; and is currently enrolled in Georgetown Law's Tax LL.M. (International Tax Certificate) program. Adnan has been admitted as a Certified Legal Specialist in Tax Law by the State Bar of California. He also is an (inactive) enrolled agent (through IRS exam).
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