8993

Section 250 Deduction for Foreign-Derived Intangible Income (FDII) and Global Intangible Low-Taxed Income (GILTI)

Agency
IRS
Revision
Rev. December 2025
Fillable fields
71
Pages
1
Official source
IRS form page
Checked
October 21, 2026
Fill 8993 online
Page 1 of form 8993

Form 8993: Section 250 Deduction for Foreign-Derived Intangible Income (FDII) and GILTI

Form 8993 is used to figure the amount of the eligible deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI) under section 250. The About page says domestic corporations use it. The instructions add U.S. individual shareholders of controlled foreign corporations (CFCs) who make a section 962 election.

The form works in three parts. Part I finds deduction eligible income (DEI) and deemed intangible income (DII). Part II finds foreign-derived deduction eligible income (FDDEI) from sales of general property, sales of intangible property and services. Part III turns those into the FDII deduction and the GILTI deduction, with reductions when FDII and GILTI together exceed taxable income.

The instructions call this a continuous use revision for tax year 2025 and later years until a superseding revision is issued. You can fill out Form 8993 free in your browser on this page and download it without an account.

What's on Form 8993

Part I: DEI and DII

Lines 1 to 8: gross income, exclusions, gross DEI, allocable deductions, DEI, deemed tangible income return (10% of QBAI) and DII.

Line 2 exclusions

Section 951(a)(1) and 951A income, financial services income, CFC dividends, domestic oil and gas extraction income, foreign branch income, and gain from sales of intangible and certain other property.

Part II: FDDEI

Lines 9 to 19 in columns for general property, intangible property and services: gross receipts, cost of goods sold, allocable and apportioned deductions, and FDDEI.

Part III: FDII and GILTI

Lines 20 to 27: foreign-derived ratio, FDII, GILTI inclusion, taxable income, and reductions when FDII and GILTI exceed taxable income.

Lines 28 and 29: deductions

The FDII deduction and the GILTI deduction, each entered here and on Form 1120, Schedule C.

How to fill out Form 8993

  1. 1

    Header

    Enter the name of the person filing the return and the identifying number.

  2. 2

    Part I

    Enter gross income from Form 1120, line 11, subtract the line 2 exclusions and allocable deductions to reach DEI, then subtract 10% of QBAI to reach DII. If DII is zero or less, the instructions say to enter zero on lines 8, 21 and 28.

  3. 3

    Part II

    Enter foreign-derived gross receipts, cost of goods sold and deductions in columns A to C, with partnership amounts on their own lines, then subtract to reach FDDEI on line 19.

  4. 4

    Lines 20 to 23

    Divide line 19 by line 6 for the foreign-derived ratio, which the instructions say may not exceed 1. Multiply line 8 by it for FDII, and enter GILTI from Form 8992, Part II, line 5.

  5. 5

    Lines 24 to 27

    Enter taxable income determined without regard to section 250. If FDII plus GILTI exceeds it, the Line 26 and Line 27 Worksheets in the instructions split the reduction between them.

  6. 6

    Lines 28 and 29

    The instructions say to multiply FDII less its reduction by 37.5% for line 28, and GILTI less its reduction, plus any section 78 dividend attributable to GILTI, by 50% for line 29.

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Where it goes, attachments and corrections

When and where

The instructions say to attach Form 8993 to the income tax return and file both by the due date (including extensions) for that return.

Attach Form 8992

For the GILTI inclusion on line 22, the instructions say to attach Form 8992 to the income tax return.

Partnership statement

Corporate partners attach a statement listing each partnership's name, EIN, the partner's share of QBAI on line 7b and other FDDEI items on lines 9b, 10b, 13 and 17.

Corrections

The instructions say a corrected Form 8993 is filed with an amended tax return, with "Corrected" entered at the top.

Deduction percentages

For tax years beginning on or after January 1, 2018, and before January 1, 2026, the instructions say section 250 generally allows 37.5% of FDII plus 50% of GILTI, reduced after that to 33.34% and 40%.

What's new

Public Law 119-21 added an exclusion from DEI for income and gain from the sale or other disposition of intangible property and certain other property, for dispositions after June 16, 2025.

Related forms

Who files Form 8993?

  • Domestic corporations

    The About page says domestic corporations use Form 8993 to figure the amount of the eligible deduction for FDII and GILTI under section 250.

  • Section 962 electing individuals

    The instructions say U.S. individual shareholders of CFCs who make a section 962 election also use the form.

  • Not REITs, RICs or S corporations

    The instructions say the deduction is allowed only to domestic corporations, not including real estate investment trusts, regulated investment companies and S corporations, and to section 962 electing individuals.

  • Corporate partners in partnerships

    A domestic corporate partner takes into account its share of partnership DEI, FDDEI, deductions and QBAI, which the instructions say is reported on Schedule K-3 (Form 1065).

The instructions say all domestic corporations, and U.S. individual shareholders of CFCs making a section 962 election, use Form 8993 to determine the allowable deduction under section 250.

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Questions about Form 8993

Who uses Form 8993?

Domestic corporations, and U.S. individual shareholders of CFCs making a section 962 election, according to the instructions. REITs, RICs and S corporations are not allowed the deduction.

Where do the deductions go?

Lines 28 and 29 say to enter the FDII deduction and the GILTI deduction on Form 1120, Schedule C.

Where does the GILTI amount come from?

The instructions say to enter the GILTI reported on Form 8992, Part II, line 5, and to attach Form 8992 to the income tax return.

What if FDII and GILTI exceed taxable income?

The instructions say the section 250 deduction is then limited to taxable income, and lines 25 to 27 split the reduction between FDII and GILTI.

What is QBAI?

Qualified business asset investment. The instructions define it as the average of the corporation's adjusted bases, as of the close of each quarter, in specified tangible property used in its trade or business and of a type for which a deduction is allowable under section 167. Line 7a uses 10% of it.

Which tax years does this revision cover?

The instructions say to use them for tax year 2025 and subsequent years until a superseding revision is issued.