Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues


No 245A DRD for Dividends from a SFC to a CFC

2024-09-12

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Last week the IRS published CCA 202436010. The CCA concludes, despite explicit legislative history suggesting otherwise, that no dividends received deduction is a allowed for dividends received by a controlled foreign corporation ("CFC") from a specified 10-percent owned foreign corporation ("SFC").

We created a chart for CCA 202436010.

Tags: 245A Dividends Received Deduction, Charts - Situational Charts