The IRS said Thursday it will issue proposed regulations detailing the breadth of an exclusion created by Republicans’ $3.4 trillion tax-and-spending law for a deduction companies can take on foreign-earned income.
The proposed regulations will be on the application of an exclusion under Section 250(b)(3), or “deduction eligible income” under the foreign-derived deduction eligible income, or FDDEI, regime, according to Notice 2025-78.
Section 250(b)(3)(A)(i)(VII), which was added by the GOP 2025 tax law, excludes from the FDDEI deduction income that’s made from the sale or other disposition of intangible property.
Thursday’s notice gives taxpayers definitions of “sale or other disposition” ...