Finanse publiczne · 25/09/2020

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

The IRS has proposed a new rule limiting the deduction for dividends received from certain foreign corporations and clarifying the amounts eligible for the Section 954 look-through exception. The proposed rule aims to prevent tax avoidance strategies and ensure compliance with U.S. tax laws.