Sec. 250 allows domestic corporations a deduction for their “foreign-derived intangible income.” Proposed regulations that were issued earlier this year answer many outstanding questions regarding the calculation of this new deduction but also include documentation requirements that may prove onerous for some taxpayers.
Several tax benefits can accrue to taxpayers that make investments in certain low-income communities through qualified opportunity funds. A second round of proposed regulations addresses many outstanding questions about this new vehicle for taxpayer-friendly investing in distressed communities.
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.
