The U.S. IRS has released a revised international practice unit on Receipt of Dividends or Interest from a Related CFC. The issue and transaction overview of the practice unit includes the following:
Note: This Unit was revised to include the extension of the IRC 954(c)(6) look through rule for CFCs with tax years beginning before January 1, 2026. This extension was part of the Consolidated Appropriations Act of 2021. This Practice Unit supersedes the January 5, 2016, and the January 28, 20…