Internal Revenue Service November 13, 2020 – Federal Register Recent Federal Regulation Documents

Limitation on Deduction for Dividends Received From Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception; Correcting Amendment
Document Number: 2020-23632
Type: Rule
Date: 2020-11-13
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains corrections to the final regulations (Treasury Decision 9909) that were published in the Federal Register on Thursday, August 27, 2020. Treasury Decision 9909 contained final regulations under sections 245A and 954 of the Internal Revenue Code (the ``Code'') that limit the deduction for certain dividends received by United States persons from foreign corporations under section 245A and the exception to subpart F income under section 954(c)(6) for certain dividends received by controlled foreign corporations.