GILTI, Subpart F & BEATAnswered

My foreign-owned LLC sells SaaS to overseas customers — does it qualify for the FDII deduction under Section 250?

E1
emeka_1c75subscriber
May 10, 2026 0 views 1 answer
fdiisection 250form 8993saasforeign-owned c-corp

I run a Delaware LLC (taxed as a C-corp) that sells software subscriptions to enterprise customers in Europe and Asia. About 85% of revenue is foreign customers. A friend mentioned the FDII deduction (Section 250) lets U.S. corporations deduct a chunk of foreign-derived income. I want to know whether my foreign-owned LLC qualifies and how to actually compute the benefit.

Related Questions

International CorporateAnswered

I keep hearing about 'branch profits tax' for foreign-owned U.S. corporations — does it apply to a Delaware C-corp owned by an NRA?

I'm a non-resident alien sole shareholder of a Delaware C-corp (formed via Form 8832 election from a single-member LLC). My CPA mentioned 'branch profits tax' under §884. I thought BPT only applied to...

SA
sofia_aa1d·May 10, 2026
01
International CorporateAnsweredFeatured

My foreign company (not a US LLC) does business in the US — do I file Form 1120-F or Form 5472?

I run a company incorporated in my home country — it is NOT a US LLC. We've started doing real business in the United States this year. I keep reading about Form 5472 for foreign-owned LLCs, but my en...

A4
andres_4d2a·May 8, 2026
1,5101
International CorporateAnswered

My CPA says I might make a section 962 election because of GILTI. Is that an entity change or only a tax-election change for me personally?

I am a U.S. individual who owns a foreign corporation directly. My CPA said section 962 might help because of the GILTI inclusion, but I keep hearing people describe it almost like creating a temporar...

HC
harper_c8ab·Dec 17, 2025
1,9181
International CorporateAnswered

How are foreign-currency gains and losses on my U.S. LLC's intercompany payable to me as the foreign owner treated under Section 988?

My U.S. LLC owes me $30,000 USD as the foreign owner; the payable is denominated in U.S. dollars. My home accounting is in euros. Between when the payable was booked and when it was paid, USD/EUR move...

LB
lin_beff·May 11, 2026
01
International CorporateAnswered

BEAT $500M gross receipts test — am I really exempt as a small foreign-owned LLC?

I've been reading scary articles about the Base Erosion and Anti-Abuse Tax (BEAT) under §59A and worrying whether my foreign-owned U.S. LLC is exposed when it pays my foreign parent for services. The ...

D2
dmitri_2bff·May 8, 2026
01
International CorporateAnswered

What is the branch profits tax and will my foreign corporation owe it?

I keep seeing 'branch profits tax' mentioned for foreign corporations operating in the US. I run my US business directly through my foreign corporation (no US subsidiary). What is this tax, how is it ...

KA
kwame_a812·May 19, 2026
1,7201
International CorporateAnswered

Foreign-corp branch vs US C-corp — which second-level tax is worse?

I'm deciding how to structure my US operations: run them directly through my foreign corporation as a branch, or set up a US C-corporation owned by my foreign parent. I understand the first level of t...

V3
viktor_3c47·May 27, 2026
1,4501
International CorporateAnswered

My foreign corporation owns a US LLC — do I file BOTH Form 1120-F and Form 5472?

Structure: a corporation in my home country owns a US single-member LLC. The LLC is disregarded. I've been filing Form 5472 with the pro forma 1120 for the LLC every year and assumed that covered ever...

M7
mei_7f30·May 13, 2026
1,3401
International CorporateAnswered

I have GILTI, but I am just an individual and did not make a section 962 election. Do I still file Form 8993?

I keep seeing online comments that GILTI comes with a section 250 deduction, and that makes people say 'just file Form 8993.' But I am not a domestic corporation, and I have not made a section 962 ele...

MC
mason_c7b2·Dec 18, 2025
1,7311
International CorporateAnswered

What's the minimum interest rate I need to charge my Wyoming LLC on a 2026 owner loan?

I want to lend $80,000 from my personal account in Germany to my foreign-owned single-member Wyoming LLC for a 3-year term. I know there's some IRS minimum interest rate I have to charge or there's an...

L1
lukas_1ec0·May 24, 2026
01

Have a similar question?

ForeignLLCTax members get expert answers with IRS citations. One CPA consultation costs $200+. Full access is $9.99/month.

Become a Member — $9.99/mo

Disclaimer: All content on ForeignLLCTax.com is created by a tax professional and is provided for general educational and informational purposes only. It does not constitute tax, legal, or accounting advice, and should not be relied upon as such. Every tax situation is different — for advice specific to your circumstances, please consult a licensed CPA, Enrolled Agent, or tax attorney. By using this website, purchasing a subscription, or accessing any tools or services, you acknowledge that no client-professional relationship is established between you and ForeignLLCTax.com or its operators. This website is not affiliated with the IRS.

Watch the walkthroughs