Maximizing FDII tax savings requires simultaneous attention on the following three interrelated computational levers:
1. Calculating intangible income attributable to Deduction Eligible Income (“DEI”)
2. Identifying all qualified Foreign-Derived Deduction Eligible Income (FD-DEI”) export receipts including both direct and indirect sales, component sales, leases, and services.
3. Selection of appropriate allocation and apportionment methodology in accordance with Treas. Reg. Section 1.861-8, including the interplay with GILTI, FTC and other statutory groupings.
Forte leverages its proprietary VantagePoint software in delivering this service.