Section 245a

Shareholder a 100 dividends received deduction the section 245a drd with respect to the foreign source portion of a dividend received from a specified 10 owned foreign corporation sfc provided certain requirements are met e g the holding period in section 246 c and that the dividend is not a hybrid dividend as defined in section 245a e.

Section 245a. For more information refer to section 245 i of the immigration and nationality act ina. Section 245a e generally limits the participation exemption deduction under section 245a or causes a dividend received by a controlled foreign corporation cfc to be included in subpart f income if a dividend from a cfc is a hybrid dividend and section 267a generally eliminates deductions for any disqualified related party amount paid or accrued through a related hybrid entity or transaction. 9909 temporary and proposed regulations originally issued last year under section 245a that treat as taxable dividends not eligible for the section 245a dividends received deduction amounts paid from earnings and profits e p generated from specified transactions that the government views as abusive.

On june 18 2019 treasury published temporary regulations td 9865 under sections 245a 954 c 6 and 6038 in the federal register 84 fr 28398 as corrected at 84 fr 38866. Deduction for foreign source portion of dividends received by domestic corporations from specified 10 percent owned foreign corporations 26 u s. Citizenship and immigration services uscis is issuing policy guidance addressing the general policies and procedures of adjustment of status as well as adjustment under section 245 a of the immigration and nationality act ina.

You must complete supplement a to form i 485 application to register permanent residence or adjust status to apply under section 245 i provisions and submit it with your form i 485. Effective august 27 the treasury and irs have finalized t d. Treasury and the irs on june 14 2019 released 105 page temporary regulations the temporary regulations under section 245a as enacted by the 2017 tax reform legislation the act.

245a a in general in the case of any dividend received from a specified 10 percent owned foreign corporation by a domestic corporation which is a united states shareholder with respect to such foreign corporation there shall be allowed as a deduction an amount equal to the foreign source portion of such dividend.