Tax Coda

Tax Coda

IRS explains how FDII rules carve out gains from IP and asset sales

IRS Notice 2025-78 (Dec. 05, 2025)

Tax Coda's avatar
Tax Coda
Dec 09, 2025
∙ Paid

In IRS Notice 2025-78, the IRS explains how a new statutory change affects deduction eligible income (DEI), which is the base number a domestic corporation uses to calculate its FDII deduction under §250.

DEI is simply the corporation’s gross income after removing specific categories of income that Congress says don’t count for FDII, and after subtracti…

User's avatar

Continue reading this post for free, courtesy of Tax Coda.

Or purchase a paid subscription.
© 2026 Tax Coda · Publisher Terms
Substack · Privacy ∙ Terms ∙ Collection notice
Start your SubstackGet the app
Substack is the home for great culture