Which taxpayer is likely to benefit from the Foreign Derived Intangible Income ("FDII") tax deduction enacted into law as part of the TCJA?

Any CPA firm that provides accounting or tax services to its U.S. clients with respect to the foreign operations of those clients.

Any U.S. taxpayer who sells property to a foreign person for use outside of the U.S.

Any foreign taxpayer that engages in a U.S. trade or business that generates effectively connected income.

Any domestic corporation which sells property to foreign persons for use outside the U.S., or provides services to persons, or with respect to property, located outside the U.S.