Burdensome Documentation Requirements Modified under the Final Section 250 Regulations
The US Office of the Treasury (Treasury) and the Inner Income Services (IRS) have issued highly anticipated steerage (the Ultimate Polices) regarding the substantiation necessities necessary to assert a segment 250 deduction with respect to international-derived intangible earnings. The Ultimate Polices drastically modified the proposed documentation necessities issued in March 2019 (the Proposed Polices), generally allowing taxpayers a lot more versatility to substantiate their transactions…
By: McDermott Will & Emery
