FDII Controversies Likely to Bubble up This Year

Tax attorney Joshua Odintz spoke with Law360 about possible foreign-derived intangible income (FDII) deduction disputes in the Internal Revenue Service (IRS) appeals process. Certain questions about FDII deductions are left for taxpayers to assess, which the IRS could challenge in an appeal process or court. Mr. Odintz explained that FDII disputes are likely to arise in U.S. Tax Court within the next two years for taxpayers and public U.S. companies. 

"We will likely start seeing proposed assessments now if a taxpayer has agreed to disagree with the IRS," he said.

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