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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 DateJanuary 4, 2022
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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Patrick McCormick is a Principal attorney in Offit Kurman’s Business Law & Transactions group, focusing his practice entirely on international tax matters. Mr. McCormick represents both business and individual clients on all aspects of United States international tax rules, both from an income tax and estate/gift tax perspective. Mr. McCormick has worked with clients in over 80 countries on American tax considerations of multinational activities, cultivating specialized knowledge in every area of United States multinational tax rules. His narrow focus has facilitated expertise in the field, trusted by clients and advisors around the world to obtain optimal results on international tax matters.

Mr. McCormick is regarded as a primary and prolific authority on American-side international tax matters. He speaks regularly on all aspects of international tax to tens of thousands of attendees annually, functioning as the primary international tax resource for national organizations including CPAacademy.org, Strafford, Lawline, and Leimberg Information Services. He is a regular contributor to America’s premier tax law publications, including Tax Notes, Journal of Taxation, Tax Notes International, and Law360.

Mr. McCormick published his first treatise on international tax matters, Allocation and Apportionment Rules Under Secs. 861-865, for Thomson Reuters’ Catalyst platform, in October 2021. In late 2021, he also released a 15-hour digital course entirely dedicated to nonresident taxation, United States Tax Considerations for Nonresident Taxpayers. Mr. McCormick has been named a Super Lawyers Rising Star from 2016-2022.

Mr. McCormick counsels a range of clients from individuals to businesses with their international tax and legal needs. When counseling individual clients, Mr. McCormick assists with residency planning, asset ownership structuring, and minimization of global income tax bills for foreign-sourced income items. His business client representation includes an extensive scope of multinational transactions, including classification of foreign entities, options for structuring multinational transactions, and minimization of American anti-deferral tax mechanisms. Mr. McCormick’s specific and comprehensive practice allows him to assist clients when international factors are most relevant.
 

 

 

About Our Presenter

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Offit Kurman is one of the fastest-growing full-service law firms in the United States. With offices in seven states and the District of Columbia, Offit Kurman is well-positioned to meet the legal needs of dynamic businesses and the individuals who own and operate them. For over 30 years, they’ve represented privately held companies and families of wealth throughout their business life cycles.