On 5 November 2018, a document containing proposed regulations for Internal Revenue Code section 956  (REG-114540-18) was published in the U.S. Federal Register. The proposed regulations 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). The proposed regulations are to apply for taxable years of a CFC beginning...