The IRS and Treasury has issued final regs under Code Secs. 245A and 954. The final regs do the following:
- Limit the deduction for certain dividends received by US persons from foreign corporations under Code Sec. 245A; and
- Limit the exception to subpart F income under Code Sec. 954(c)(6) for certain dividends received by controlled foreign corporations.
Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal..