This legislation aims to prevent a scheduled reduction in the tax deduction for foreign-derived intangible income (FDII) . By amending Section 250(a)(3) of the Internal Revenue Code, the bill ensures that the deduction for FDII remains at its current rate of 37.5% for domestic corporations, rather than decreasing after December 31, 2025, as previously mandated. Specifically, the bill strikes the existing language in Section 250(a)(3) that outlined future deduction rate changes for both FDII and global intangible low-taxed income (GILTI) . In its place, the amendment introduces a new provision that immediately reduces the GILTI deduction from 50% to 37.5% upon the bill's enactment. This change means that while the FDII deduction is preserved at its higher rate, the GILTI deduction is lowered sooner than originally scheduled.
Growing and Preserving Innovation in America Act of 2024
Introduced in House
Referred to the House Committee on Ways and Means.
Taxation
Growing and Preserving Innovation in America Act of 2025
USA119th CongressHR-1062| House
| Updated: 2/6/2025
This legislation aims to prevent a scheduled reduction in the tax deduction for foreign-derived intangible income (FDII) . By amending Section 250(a)(3) of the Internal Revenue Code, the bill ensures that the deduction for FDII remains at its current rate of 37.5% for domestic corporations, rather than decreasing after December 31, 2025, as previously mandated. Specifically, the bill strikes the existing language in Section 250(a)(3) that outlined future deduction rate changes for both FDII and global intangible low-taxed income (GILTI) . In its place, the amendment introduces a new provision that immediately reduces the GILTI deduction from 50% to 37.5% upon the bill's enactment. This change means that while the FDII deduction is preserved at its higher rate, the GILTI deduction is lowered sooner than originally scheduled.