U.S. IRS Releases Revised Practice Unit on the Receipt of Dividends or Interest from a Related CFC
The U.S. IRS has released a revised international practice unit on the Receipt of Dividends or Interest from a Related CFC. The practice unit was revised to include the extension of the IRC 954(c)(6) look through rule for CFCs with tax years beginning before 1 January 2021 as part of the Taxpayer Certainty and Disaster Tax Relief Act of 2019. The practice Unit supersedes the unit of the same t…
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