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Transfer Pricing Report

Final IRS Dividend Deduction Rules Slated for Early Spring

Jan. 23, 2020, 5:27 PM

The Treasury Department in the spring hopes to release final rules for the 2017 tax law’s limit on the dividend write-off a U.S. corporation gets from a foreign company in which it owns shares.

Treasury will follow those rules with a set of proposed regulations addressing other technical aspects of the deduction under Section 245A, James S. Wang, attorney-adviser at Treasury’s Office of Tax Policy, said at a conference hosted by the D.C. Bar on Thursday.

The IRS in June released temporary (T.D. 9865) and proposed (REG-106282-18) rules governing that code section, which...

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