Treasury Decision 9909 – Limitation on Deduction for Dividends Received from Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception

The IRS and Treasury has issued final regs under Code Secs. 245A and 954. The final regs do the following: 

1. Limit the deduction for certain dividends received by US persons from foreign corporations under Code Sec. 245A; and
2. Limit the exception to subpart F income under Code Sec. 954(c)(6) for certain dividends received by controlled foreign corporations.

Click here to see Treasury Decision 9909 and final regs.

Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.