Discuss the risks associated with Foreign Derived Intangible Income (FDII)? What issues should a corporation consider in modelling the FDII deductions. How does a company prepare for an audit?

Include the new International Tax provision: Foreign Derived Intangible Income.  Provide to their respective companies and clients to understand the new provision. Based on the Department of Treasury's Final Regulations on Foreign Derived Intangible Income in July 2020, provide a brief discussion of FDII from one's perspective and then a detailed discussion of the following:

List the top 10 compliance risks related to FDII.
Discuss these risks and risk management issues associated with FDII?
How do the documentation requirements impact your risk analysis?
How burdensome are these documentation requirements?
What are the risks for small businesses vs. large businesses?
What are the risks related to the allocation method used to calculate the FDII Deduction? How do the allocation rules impact your risk analysis?
What are the risk considerations with keeping production in the US verses placing business overseas?
Discuss the related party risks.
What are the risks related to FDII's interrelationship to other provisions of the IRC?
Discuss the ordering rules.