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 dividends received from "Specified 10-percent owned Foreign Corporations". The facts and conclusion are summarized in the memorandum as follows: --- Subject: Application of Section 245A(a) to Dividends Received by a CFC This memorandum provides non-taxpayer-specific legal advice regarding the...