Tax News Update    Email this document    Print this document  

May 6, 2022

IRS Chief Counsel Memorandum addresses proper allocation and apportionment of deferred compensation expense in calculating FDII deduction

In a new Chief Counsel Memorandum (AM 2022-001), the IRS addresses how to properly allocate and apportion deferred compensation expense (DCE) under the IRC Section 861 regulations for calculating a taxpayer's foreign derived intangible income (FDII) deduction.