This week, Steve and Loren discuss the final FDII regulations from July with Jeff Tebbs, International Tax Counsel at Lockheed Martin. They cover:Allocation of R&E expenses, which Treasury did not addressFinalized regulations treating 250(b) as operative under 861 allocation and apportionment rulesSales of general property that primarily contain digital contentHow final regulations relax documentation and substantiation requirements Thanks to our guest Jeff Tebbs for joining us: https://www.linkedin.com/in/jtebbs/ *********Questions? Contact us at [email protected] break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you’ll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.Apple Podcasts: https://apple.co/2WAZXPy Spotify: https://spoti.fi/2T9wJVW Google Podcasts: https://bit.ly/3639emF Stitcher: https://bit.ly/2Tpals3