Treasury and IRS Release Final and Proposed Regulations under Section 245A
On August 21, the Department of the Treasury and the Internal Revenue Service released proposed and final regulations under section 245A. Section 245A allows a 100% deduction to a corporate US shareholder for the foreign-source portion of dividends received from a specified 10% owned foreign corporation (SFC). The final regulations limit the deduction for certain dividends received by United States persons from foreign corporations under section 245A and the look-through rule in section 954(c)(6) for certain dividends received by controlled foreign corporations. The proposed regulations coordinate the extraordinary disposition rule under section 245A with the disqualified basis rule under section 951A, relating to global intangible low-taxed income (GILTI).
Read More: Final Regulations
Read More: Proposed Regulations