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Form 8993: Section 250 Deduction for Foreign-Derived Intangible Income (FDII) and Global Intangible Low-Taxed Income (GILTI)
IRS Form 8993 is used to calculate the Section 250 Deduction for Foreign-Derived Intangible Income (FDII) and Global Intangible Low-Taxed Income (GILTI). The deduction is allowed only to domestic corporations or section 962 electing individuals.
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IRS Form 8993 - Section 250 Deduction for Foreign-Derived Intangible Income (FDII) and Global Intangible Low-Taxed Income (GILTI)
IRS Form 8993 is used to calculate the Section 250 Deduction for Foreign-Derived Intangible Income (FDII) and Global Intangible Low-Taxed Income (GILTI). The deduction is allowed only to domestic corporations or section 962 electing individuals.
Risk Radar
Scan points- 1Ensure you use the current edition; the latest revision is December 2025.
- 2Failing to exclude items correctly when determining Deduction Eligible Income (DEI) in Part I.
- 3Omitting amounts provided in items 7 and 8 from Part I, line 2 when calculating DEI.
- 4Entering gross receipts into the wrong columns of Part II (General Property vs. Services).
- 5Not attaching Form 8992 when reporting GILTI on Line 24.
Plain English
This form helps a business figure out how much of its income derived from foreign sources qualifies for a special tax break under Section 250. By completing Form 8993, the filer determines the eligible deduction amount for both Foreign-Derived Intangible Income (FDII) and Global Intangible Low-Taxed Income (GILTI).
Submission Date
- Filing date: 2026-01-08 16:10:44
- Preparation window: collect IDs, supporting records, and signatures in advance.
- Final review: verify names, dates, and required fields before submission.
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What this form is for
- Use this form when a domestic corporation or a U.S. individual shareholder of controlled foreign corporations (CFCs) making a section 962 election must determine the allowable deduction under section 250.
- Do not use Form 8993 when you are an S corporation, a real estate investment trust (REIT), or a regulated investment company (RIC).
- Check Form 8992 instead when determining information related to Global Intangible Low-Taxed Income (GILTI) for U.S. shareholders of controlled foreign corporations (CFCs).
Form selector
Use this form or another form?
Partnership member
Use this form to calculate the deduction amount for a domestic corporation that is a partner in a partnership.
✓ Check Regulations sections 1.250(b)-1(e) and 1.250(b)-3(e)
Tax year beginning before 2018/after 2026
The standard deduction percentages are different for tax years starting on or after January 1, 2018, but before January 1, 2026.
✓ Check Instructions p.1
Tax year 2025
Use these specific instructions for the current tax year until a superseding revision is issued.
✓ Check Instructions p.1
Deadline or filing window
The filing deadline for Form 8993 is the due date of the associated income tax return, including any extensions. If an extension is filed, the form must still be submitted by that extended date to claim the deduction.
Checklist
What you need before filling it out
Gross income (Line 1)
Amount from Form 1120, line 11 · Part I: Determining DEI and DII
Exclusions (Lines 2a-2e)
Specific types of income/gain listed in the form section · Part I: Determining DEI and DII
Domestic Corporation Status
The entity filing the return · General Instructions p.1
Deduction Limit Rule
Sum of FDII and GILTI exceeding taxable income · Instructions p.1
Pre-2026 Deduction Rates
37.5% for FDII + 50% for GILTI (for years starting Jan 1, 2018 - Dec 31, 2025) · Instructions p.1
Future Development Info
IRS.gov/Form8993 · Instructions p.1
Before you submit
- 1Ensure all required fields in Part I (determining DEI and DII) are completed.
- 2Verify the amount entered on Line 1 matches Form 1120, line 11.
- 3Confirm that exclusions listed on Lines 2a through 2e have been properly deducted from Gross Income.
- 4Check if the sum of FDII and GILTI exceeds taxable income to confirm the deduction limitation applies.
- 5Verify that the correct deduction percentage (37.5%/50% or 33.34%/40%) is used based on the tax year.
- 6Ensure the form is attached to your main income tax return, filing by the due date.
- 7Confirm the revision date reads December 2025.
How to file this form
- 1Determine Deduction Eligible Income (DEI) first, which involves calculating Gross Income less deductions properly allocable to that gross income.
- 2Calculate Deemed Tangible Income Return (DTIR), then determine Deemed Intangible Income (DII).
- 3Compute Foreign-Derived Deduction Eligible Income (FDDEI) and subsequently the Foreign-Derived Ratio (FDR).
- 4Determine FDII, and if necessary, calculate the reductions for both FDII and GILTI due to excess over taxable income.
- 5Finally, determine the eligible deduction under section 250 and attach Form 8993 to your income tax return.
Known limitations
- 1The deduction under IRS Form 8993 is allowed only to domestic corporations that are not real estate investment trusts (REITs), regulated investment companies (RICs), or S corporations.
- 2The deduction is also allowed to section 962 electing individuals.
- 3For transactions involving related parties, special rules for determining foreign use apply (see section 250(b)(5)(C) and Regulations section 1.250(b)-6).
- 4When calculating exclusions described in Part I, line 2, sale or other disposition does not include any lease or license.
Field map
Compact field-by-field guide
Entity Info
1 items
Name and taxpayer ID of the entity claiming the credit.
Credit Info
1 items
Type of credit or incentive being claimed.
Calculation
2 items
The base amount used to calculate the credit.
Calculated credit amount after applying formulas and limitations.
Certification
1 items
Detailed breakdown supporting the credit calculation.
Signatures
1 items
Sign and date the form.
Almost done reviewing the fields?
Fillable formOpen in Editor->The current edition is Revision December 2025, and users should visit IRS.gov/Form8993 for the latest information regarding Form 8993. Public Law 119-21 amended section 250 by adding an exclusion related to income from intangible property (as defined in section 367(d)(4)) and other depreciable/amortizable/depletable property.
What changed or needs a fresh check
- Edition date — confirm the revision date reads December 2025.
- Official Title — confirm the title reads Section 250 Deduction for Foreign-Derived Intangible Income (FDII) and Global Intangible Low-Taxed Income (GILTI).
- Mailing address — confirm the address is Internal Revenue Service, Attention: Substitute Forms Program, C:DC:TS:CAR:MP:P:TP:TP, ATSC, 4800 Buford Highway, Mail Stop: 061-N, Chamblee, GA 30341.
- Purpose — confirm the form allows a deduction for the eligible percentage of FDII and GILTI under section 250.
Quick Facts
Downloads
After you file
- 1Keep a copy of IRS Form 8993 (Rev. December 2025) for record-keeping.
- 2The form is approved under OMB control number 1545-0123 and this number is included in the estimates shown in the instructions for the business income tax return with which it is filed.
- 3If comments regarding the accuracy of time estimates or suggestions for simplifying IRS Form 8993 are provided, they should be directed to the IRS (referencing the instructions for the associated tax return).
- 4The form's revision date is December 2025, and taxpayers should confirm this when filing.
Sources
- SRCInstructions p.1 — The purpose of IRS Form 8993 is to allow a deduction for the eligible percentage of FDII and GILTI under section 250.
- SRCInstructions p.1 — All domestic corporations (excluding REITs, RICs, S corps) and section 962 electing individuals must use this form.
- SRCInstructions p.1 — FDDEI means deduction eligible income derived from property sold to a foreign person for foreign use or services provided outside the United States.
- SRCInstructions p.2 — 'Foreign use' is defined as any use, consumption, or disposition that is not within the United States.
- SRCInstructions p.3 — For Part I, line 9b (Gross Receipts From Partnerships), enter the amount of the partner’s share of foreign-derived gross receipts from all sales of general property in Column A.
- SRCForm p.1 — The form's revision date is December 2025 and its catalog number is 37817J.
Common confusion points
What qualifies as 'Foreign Use'?
It means any use, consumption, or disposition that occurs outside the United States.
→ Confirm this definition matches the requirements in Regulations section 1.250(b)-4(d).
When calculating FDII/GILTI, what does 'FDDEI' mean?
FDDEI stands for deduction eligible income derived from property sold to a foreign person for foreign use, or services provided outside the United States.
Do all sales count when determining gross receipts?
No; amounts provided in items 7 and 8 of Part I, line 2 are excluded when entering amounts on page 3.
What is 'intangible property' for exclusion purposes?
It is defined in section 367(d)(4) and includes income/gain from its sale or disposition occurring after June 16, 2025 (if applicable).
Does a lease count as a sale when determining foreign use?
No; the term 'sale' includes any lease, license, exchange, or other disposition, but for exclusions in Part I, line 2, it specifically does not include a lease or license.
What is the general purpose of IRS Form 8993?
To figure out the amount of the eligible deduction for FDII and GILTI under section 250.
Workflow map
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⚠ If something goes wrong
- Taxpayers should refer to the instructions for their specific business income tax return when filing IRS Form 8993.
Questions about IRS Form 8993
What is IRS Form 8993 used for?
This form helps a business figure out how much of its income derived from foreign sources qualifies for a special tax break under Section 250. By completing Form 8993, the filer determines the eligible deduction amount for both Foreign-Derived Intangible Income (FDII) and Global Intangible Low-Taxed Income (GILTI).
Who must file IRS Form 8993?
All domestic corporations, including U.S. individual shareholders of controlled foreign corporations (CFCs) making a section 962 election (962 electing individual), must use Form 8993.
What information does IRS Form 8993 require?
The form collects various financial figures across its parts, such as the Gross Income (Line 1), Foreign-Derived Deduction Eligible Income (FDDEI), and the amount of GILTI reported on Form 8992 (Line 24).
When is IRS Form 8993 due?
Form 8993 must be attached to an income tax return and filed by the due date (including extensions) for that return.
Where do I file IRS Form 8993?
The form can be mailed to Internal Revenue Service, Attention: Substitute Forms Program, C:DC:TS:CAR:MP:P:TP:TP, ATSC, 4800 Buford Highway, Mail Stop: 061-N, Chamblee, GA 30341. It can also be submitted electronically via [email protected].
How do I complete IRS Form 8993?
First, determine Deduction Eligible Income (DEI) in Part I. Next, calculate Deemed Intangible Income (DII). Then, fill out Part II by entering foreign-derived gross receipts from sales of intangible property and services. Finally, the form determines the eligible deduction under section 250.
What happens if IRS Form 8993 is filed incorrectly?
The deduction is allowed only to domestic corporations (excluding REITs, RICs, and S corps) and section 962 electing individuals; failing this requirement means the calculation may not apply correctly.
What qualifies as 'Foreign Use'?
It means any use, consumption, or disposition that occurs outside the United States. Confirm this definition matches the requirements in Regulations section 1.250(b)-4(d).
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