Code of Federal Regulations Title 26. Internal Revenue § 26.1.250–1 Introduction

(a) Overview.Sections 1.250(a)–1 and 1.250(b)–1 through 1.250(b)–6 provide rules to determine a domestic corporation's section 250 deduction.Section 1.250(a)–1 provides rules to determine the amount of a domestic corporation's deduction for foreign-derived intangible income and global intangible low-taxed income.Section 1.250(b)–1 provides general rules and definitions regarding the computation of foreign-derived intangible income.Section 1.250(b)–2 provides rules for determining a domestic corporation's qualified business asset investment.Section 1.250(b)–3 provides general rules and definitions regarding the determination of gross foreign-derived deduction eligible income.Section 1.250(b)–4 provides rules regarding the determination of gross foreign-derived deduction eligible income from the sale of property.Section 1.250(b)–5 provides rules regarding the determination of gross foreign-derived deduction eligible income from the provision of a service.Section 1.250(b)–6 provides rules regarding the sale of property or provision of a service to a related party.

(b) Applicability dates. Except as provided in the next sentence, §§ 1.250(a)–1 and 1.250(b)–1 through 1.250(b)–6 apply to taxable years beginning on or after January 1, 2021.Section 1.250(b)–2(h) applies to taxable years ending on or after March 4, 2019. However, taxpayers may choose to apply §§ 1.250(a)–1 and 1.250(b)–1 through 1.250(b)–6 for taxable years beginning on or after January 1, 2018, and before January 1, 2021, provided they apply the regulations in their entirety (other than § 1.250(b)–3(f) and the applicable provisions in § 1.250(b)–4(d)(3) or § 1.250(b)–5(e)(4)), but once applied, taxpayers must apply the final regulations for all subsequent taxable years beginning before January 1, 2021.