0325 Publ 6076 (PDF)

Official source: IRS Forms, Instructions & Publications (https://www.irs.gov/pub/irs-pdf/p6076.pdf), retrieved 2026-10-03. U.S. Government work (17 U.S.C. § 105).

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U.S. corporations use Form 8993, Section 250 Deduction for Foreign-Derived Intangible Income (FDII) and Global Intangible Low-Taxed Income (GILTI), to determine their eligible FDII and GILTI deductions under Section 250, created under Public Law 115-97 (Tax Cuts and Jobs Act (TCJA) of 2017). FDII is income from accessing or serving foreign markets, either through goods or services, and is already included as part of a domestic corporation’s taxable income. The GILTI provisions in IRC Section 951A impose a tax on foreign sourced intangible income earned by U.S. shareholders of any controlled foreign corporation (CFC). The GILTI provisions in Section 250 allow a deduction on income generated by intangible assets owned outside of the U.S.

For tax years 2018–2025, certain domestic corporations are allowed a deduction equal to 37.5% of FDII and 50% of GILTI. The IRS Statistics of Income Division (SOI) produced a sample-based collection of aggregate statistics for corporation income tax returns with a Form 8993 that were included in the tax year 2021 SOI sample of corporation returns with accounting periods ending between July 2021 and June 2022.

• U.S. corporations claimed over $111 billion in FDII deductions and over $311 billion in GILTI deductions in tax year 2021.

• U.S. corporations reported over $301 billion of FDII on Form 8993.

• The top 5 industries accounted for almost 90% of the GILTI deduction total and 92% of the FDII deduction total.

• The manufacturing industry reported a FDII amount of over $146 billion, the most of any industry and 48.6% of total FDII reported for all industries. The manufacturing industry claimed 55.9% of the GILTI deduction total.

• The information industry claimed 15.6% of the GILTI deduction total and 29.5% of the FDII deduction total.

FDII and GILTI Deductions for Top Industries, Tax Year 2021

Percentage of FDII and GILTI Deductions by Industry, Tax Year 2021

100%

All other industries

Manufacturing

Information

Finance and Insurance

Retail Trade

Wholesale Trade

All other industries

0 $20B $40B $60B $80B $100B $120B $140B $160B $180B

FDII Deduction

90%

80%

70%

60%

50%

40%

30%

20%

10%

0

Wholesale Trade

Retail Trade

Finance and Insurance

Information

Manufacturing

GILTI Deduction

Tax Statistics Publication 6076 (Rev. 3–2025) Catalog Number 95609P Department of the Treasury Internal Revenue Service www.irs.gov