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Released on 11 October, 2024, GLAM 2024-002 introduces the IRS's position that it may use section 246(b) to disallow some of a taxpayer's section 250 deductions (i.e., FDII and GILTI deductions) during years in which the taxpayer has profitable foreign operations but otherwise unprofitable US operations. Some taxpayers are already beginning to explore options to combat the GLAM's interpretation of section 246(b). Baker McKenzie Tax partners Ethan Kroll, Sam Pollack, and John Barlow discuss the GLAM's reliance on a flawed statute and the need for courts to weigh in and resolve open issues in their most recent article, "IRS Sends Statutory Frankenstein to Take Your §250 Deductions", published yesterday in Bloomberg Tax's Tax Management International Journal.
Click here to download the article.
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