The U.S. IRS and Treasury have issued final regulations on the Limitation on Deduction for Dividends Received from Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception (TD 9909). In addition, related proposed regulations have been issued on the Coordination of Extraordinary Disposition and Disqualified Basis Rules (REG-124737-19). Both regulations were published in the Federal Register on 27 August 2020. --- Limitation on Deduction for Dividends Received from Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception SUMMARY: This document contains final regulations under sections 245A and 954 of the Internal Revenue Code (the "Code") that...