tax break: Final FDII Regulations (Part 2)

tax break Podcast


In this episode of tax break, Steve and Loren discuss the final FDII regulations from July 2020 with Sharon Heck, Treasurer and Chief Tax Officer at Intel. They discuss several aspects of the business that have been affected by FDII, and policy discussion underscoring the importance of the provision now and going forward:

  1. Practical considerations (supply chain considerations, corollary to GILTI, impact to M&A transactions)
  2. Policy considerations (Biden tax proposals – Made in America, R&D innovation and incentivization, impact of impending R&D amortization provision)

Thanks to Sharon Heck for joining us.

Questions? Contact us at

tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.

tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you'll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts: Apple Podcasts | Spotify | Google Podcasts | Stitcher | YouTube