Layla Asali Quoted Regarding Treasury's Proposed Section 250 Regulations in Law360

"Individuals Can Get Foreign Tax Deduction, Treasury Says"



Layla Asali was quoted on proposed rules released by the U.S. Department of Treasury and IRS relating to newly enacted deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI). The proposed regulations provide a series of rules and tests that companies have to satisfy to verify that their income was derived from foreign sales and foreign services. Asali said statute and the proposed regulations "puts a lot of pressure on this categorization of sales versus service."