Eligibility Requirements For Reduced Tax Rate On FDII For Royalties


David Noren, Lowell Yoder and Elizabeth Chao authored this bylined article on the taxation of royalty income derived from business conducted outside the United States. “A domestic corporation should carefully analyze the royalties it derives from licensing intangible property for use outside the United States and ensure that the FDII requirements are satisfied, and develop documentation supporting the applicability of the 13.125 percent tax rate,” they wrote.

This column is reprinted with the publisher’s, Wolters Kluwer, permission from Global Tax Weekly, and originally appeared at pages 16-17, August 9, 2018.