IRS Clarifies Property Sales Exclusion from FDDEI Deduction in New Proposed Regulations

The U.S. Treasury and IRS have proposed regulations that quietly redraw the boundaries of a significant corporate tax benefit, excluding from eligibility the income companies earn when they sell intangible assets or depreciated property to foreign buyers. Effective for transactions after June 16, 2025, the rules reflect a deliberate policy choice: to keep the foreign-derived deduction eligible income incentive tethered to the export of manufactured goods rather than the offshore disposition of accumulated business assets. In the long arc of tax policy, this is a familiar tension — between rewa