Finanse publiczne · 27/08/2020

IRS Finalizes Regulations on Foreign Dividend Deductions and Section 954 Look-Through Exception

The Internal Revenue Service (IRS) has released final regulations under sections 245A and 954 of the Internal Revenue Code, limiting the deduction for certain foreign dividends and the exception to subpart F income for controlled foreign corporations, as part of the Tax Cuts and Jobs Act enacted on December 22, 2017.