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U.S. Temporary and Proposed Regulations on Dividends Received Deduction Limitation

19 June 2019

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Approved Changes

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United States

On 18 June 2019, final temporary regulations from the U.S. IRS and Treasury on the Limitation on Deduction for Dividends Received from Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception were published in the Federal Register. The regulations were published and are effective on 18 June 2019, and also serve as the text of proposed regulations published the same date. --- SUMMARY: This document contains temporary regulations under section 245A of the Internal Revenue Code (the “Code”) that limit the dividends received deduction available for certain dividends received from current or former controlled foreign corporations. This document...