On 20 November 2020, the U.S. IRS and Treasury issued final regulations (TD 9934) that coordinate the "extraordinary disposition rule" under Section 245A of the Internal Revenue Code with the "disqualified basis and disqualified payment rules" under Section 951A. The final regulations also contain guidance under Section 6038 regarding information reporting to facilitate administration of the final regulations. Section 245A generally allows a domestic corporation that is a United States shareholder a 100% dividends-received-deduction (DRD) for the foreign-source portion of a dividend received after 31 December 2017 from a specified 10-percent owned foreign corporation (SFC). Section 951A requires a United...