under section 964(e) as a dividend to the selling CFC. The new law provides two loss limitationrules. First, it provides that if a U.S. shareholder that is a domestic corporation has received a dividend from a foreign corporation that is allowed a 100% DRD, solely ...

2012年8月28日 · Section 964(e) extends the Section 1248 rules to cases where the seller is, itself, a CFC. One of the underlying policies of Section 367(b) is the preservation of the potential application of Section 1248 in situations where a U.S. transferor (or a CFC transferor)

Finally, permitting a deemed dividend that results from the application of section 964(e) to qualify for look-through treatment under section 954(c)(6) is consistent with Congress’ policy of enacting section 954(c)(6) insofar as section 964(e) recognizes that stock II.

2019年2月21日 · Another significant distinction arises under Section 964(e)(4), which now has the effect of recharacterizing gain from the sale of lower-tier CFC interests by an upper-tier CFC as Subpart F income ...

New 964(e)(4) Finally, the participation exemption of 245A was also extended to sales of lower-tier CFC stock by an upper-tier CFC where the application of 1248 and 964(e) results in a deemed dividend. As above, as-sume that the fact pattern is that the U

2017年12月21日 · For taxable years beginning after Dec. 31, 2025, two changes are made (1) the 10 percent provided for above is changed to 12.5 percent, and (2) the regular tax liability is reduced by the aggregate amount of the credits allowed under Chapter 1 (and no other adjustment is made). (See below example for illustrative purposes.)

2018年12月28日 · Disallowance of certain interest and royalty deductions. (a) Scope. This section and §§ 1.267A-2 through 1.267A-5 provide rules regarding when a deduction for any interest or royalty paid or accrued is disallowed under section 267A. Section 1.267A-2 describes hybrid and branch arrangements.

Section 959(a) provides that earnings and profits (“E&P”) of a CFC that have already been taxed to a U.S. Shareholder under Section 951(a) (such previously taxed income, “PTI”) will not be taxed again when distributed to that shareholder (or, in certain

New section 245A(e) denies the benefit of the section 245A dividends received deduction (DRD) to certain “hybrid dividends,” thus treating such items as taxable at ordinary rates. This treatment also applies to “tiered dividends” between controlled foreign corporations (CFCs), by treating the dividend as subpart F income in the recipient CFC.

Form 5471. Form 5471 is required by US Person Shareholders, Directors, and Officers of International/Foreign Corporations who have an ownership interest or control in the entity. The requirements of reporting foreign corporations and other entities fall under Internal Revenue Code sections 6038 and 6046. There are five (5) main categories of ...