8993 Section 250 Deduction for Foreign-Derived Intangible Inc

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8993

Form
(December 2018)
Department of the Treasury
Internal Revenue Service
Name of person filing this return

Part I

Section 250 Deduction for Foreign-Derived Intangible Income (FDII)
and Global Intangible Low-Taxed Income (GILTI)
▶

OMB No. 1545-0123

Go to www.irs.gov/Form8993 for instructions and the latest information.

Attachment
Sequence No. 933
Identifying number

Determining Deduction Eligible Income (DEI) (see instructions)

DRAFT AS OF
September 20, 2018
DO NOT FILE
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DEI derived from sales, leases, exchanges, or other dispositions (but
not licenses) of property to a foreign person for a foreign use (see
1a
instructions) . . . . . . . . . . . . . . . . . . . .
b DEI derived from a license of property to a foreign person for a foreign
use (see instructions) . . . . . . . . . . . . . . . . .
1b
c DEI derived from services provided to a person or with respect to
property located outside of the United States (see instructions) . . .
1c
2
Foreign Derived Deduction Eligible Income (FDDEI) (add lines 1a through 1c) . .
3
Deduction Eligible Income (DEI) (from Part I, line 6, above) . . . . . . . .
4
Foreign Derived Ratio (FDDEI / DEI) (divide line 2 by line 3) . . . . . . . .

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Gross Income . . . . . . . . . . . . . . . . . .
Exclusions
a Income included under section 951(a)(1) . . . . . . . . . .
b Income included under section 951A (from Form 8992, Part II, line 3)
c Financial Services Income . . . . . . . . . . . . . .
d CFC Dividends . . . . . . . . . . . . . . . . . .
e Domestic Oil and Gas Extraction Income . . . . . . . . .
f Foreign Branch Income . . . . . . . . . . . . . . .
3
Total Exclusions (add lines 2a through 2f) . . . . . . . . .
4
Gross Income less Total Exclusions (subtract line 3 from line 1) . .
5
Deductions properly allocable to the amount on line 4 . . . . .
6
Deduction Eligible Income (DEI) (subtract line 5 from line 4) . . .

Part II
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Determining Deemed Intangible Income (DII) (see instructions)

DEI (from Part I, line 6, above) . . . . . . . . . .
Deemed Tangible Income Return (10% of QBAI) . . . .
Deemed Intangible Income (DII) (subtract line 2 from line 1)

Part III

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Determining Foreign Derived Ratio (see instructions)

1a

Part IV
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Determining FDII and/or GILTI Deduction (see instructions)

Deemed Intangible Income (DII) (from Part II, line 3) . . . . . . . . . . . . . . . .
Foreign Derived Ratio (from Part III, line 4) . . . . . . . . . . . . . . . . . . .
FDII (multiply line 1 by line 2). . . . . . . . . . . . . . . . . . . . . . . .
Global Intangible Low-Taxed Income (GILTI) Inclusion (see instructions for line 3b) . . . . . .
Total FDII and GILTI (add lines 3a and 3b) . . . . . . . . . . . . . . . . . . .
Taxable Income (see instructions for line 4) . . . . . . . . . . . . . . . . . . .
Excess FDII and GILTI over Taxable Income (subtract line 4 from line 3c). If zero or less, enter -0here and on lines 6 and 7 . . . . . . . . . . . . . . . . . . . . . . . . .
FDII Reduction (divide line 3a by line 3c; multiply by line 5) . . . . . . . . . . . . . .
GILTI Reduction (subtract line 6 from line 5). . . . . . . . . . . . . . . . . . .
FDII Deduction (see instructions for line 8). (Enter here and on Form 1120, Schedule C; see
instructions for information on other tax forms). . . . . . . . . . . . . . . . . .
GILTI Deduction (see instructions for line 9). (Enter here and on Form 1120, Schedule C; see
instructions for information on other tax forms). . . . . . . . . . . . . . . . . .

For Paperwork Reduction Act Notice, see separate instructions.

Cat. No. 37817J

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Form 8993 (12-2018)