The Treasury is Definitely Concerned About “Gaming Transactions” Between Related CFCs During the So-Called “Disqualified Period” And Beyond

By Jerald David August, Chair, International Taxation and Wealth Planning Group

The government recently issued temporary regulations under section 245A which provides a 100% dividends received deduction (DRD) for certain dividends received by a US corporation from a current for former controlled foreign corporation (CFC) defined in section 957. The provision is frequently referred to as the participation exemption which many countries have already had in place with respect to their domestic corporations in investing in subsidiary or affiliate corporations overseas.… Continue Reading