U.S. IRS and Treasury Issue Corrections to Regulations on Deduction for Foreign-Derived Intangible Income and Global Intangible Low-Taxed Income

The U.S. IRS and Treasury have issued two correcting amendments to the final regulations (TD 9909) on the Limitation on Deduction for Dividends Received From Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception. The two correcting amendments were published in the Federal Register on 13 November 2020 and 16 November 2020 and are effective from the respective dates. Both correcting amendments are summarized as follows

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SUMMARY:

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