On 23 May 2019, the final regulations on Amount Determined Under Section 956 for Corporate United States Shareholders (TD 9859) was published in the U.S. Federal Register. The regulations finalize the proposed regulations published in November 2018 that reduce the amount determined under section 956 for certain domestic corporations that own (or are treated as owning) stock in controlled foreign corporations (CFCs) in order to ensure that the application of section 956 is consistent with the new participation exemption system (dividends received deduction) for 10% owned foreign corporations introduced by the Tax Cuts and Jobs Act (TCJA) under section 245(a)...