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IRS Office of Chief Counsel Explains a CFC Not entitled to dividends Received Deduction Under Section 245A.

|Approved Changes|United States
United States

The U.S. IRS recently released an Office of Chief Counsel memorandum explaining that a controlled foreign corporation (CFC) is not entitled to a dividends received deduction under section 245A. Section 245A allows an exemption for certain foreign income of a domestic corporation that is a U.S. Shareholder by means of a 100% dividends received deduction for the foreign source portion of dividen…

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