The U.S. IRS and Treasury have issued final regulations on the Limitation on Deduction for Dividends Received from Certain Foreign Corporations and Amounts Eligible for Section 954 Look-Through Exception (TD 9909). In addition, related proposed regulations have been issued on the Coordination of Extraordinary Disposition and Disqualified Basis Rules (REG-124737-19). Both regulations were published in the Federal Register on 27 August 2020.
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Limitation on Deduction for Dividends Receiv…