Finanse publiczne · 08/08/2019

Limitation on Deduction for Dividends Received From Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception; Correcting Amendment

The IRS has corrected temporary regulations under section 245A of the Internal Revenue Code, limiting the dividends received deduction for certain dividends from foreign corporations, and clarified the amounts eligible for the Section 954 look-through exception. The corrections were published in the Federal Register on Tuesday, June 18, 2019, in response to Treasury Decision 9865.