The US Internal Revenue Service (IRS) and the Treasury Department have issued proposed regulations that provide guidance to determine the amount of the deduction for foreign-derived intangible income and global intangible low-taxed income (GILTI), multinational law firm Dentons stated.

For purposes of determining US tax liability under the GILTI regime, Section 250 provides that a domestic corporation is allowed a deduction equal to 50 percent, or 37.5 percent for taxable years beginning after 31 December 2025, of the sum of its GILTI plus associated foreign taxes.

The proposed regulations would extend the benefit of th...