Participation exemption system
Section 956, participation exemption system
KPMG reports
- Jun 19, 2019 - KPMG report: Initial impressions of temporary regulations under section 245A; denial of dividends received deduction for certain dividends from current or former CFCs
- May 29, 2019 - KPMG report: Final regulations, amount determined under section 956 for corporate U.S. shareholders
- Nov 4, 2018 - KPMG report: Initial impressions of proposed regulations coordinating sections 956 and 245A
Final regulations
Jun 14, 2019 - Regulations: Dividends received deduction limitation when from certain foreign corporations (text of regulations)
Jun 5, 2019 - Regulations: Dividend received deduction, branch loss recapture (sections 91 and 245A); OIRA review completed
May 29, 2019 - KPMG report: Final regulations, amount determined under section 956 for corporate U.S. shareholders
May 22, 2019 - Final regulations: Amount determined under section 956 for corporate U.S. shareholders (text of regulations)
May 15, 2019 - Regulations pending OIRA review: Dividend received deduction (section 245A), branch loss recapture (section 91)
Proposed regulations
Oct 8, 2019 - Public hearing scheduled; regulations on dividends received deduction limitations from controlled foreign corporations
Jun 14, 2019 - Regulations: Dividends received deduction limitation when from certain foreign corporations (text of regulations)
Jun 5, 2019 - Regulations: Dividend received deduction, branch loss recapture (sections 91 and 245A); OIRA review completed
May 30, 2019 - Regulations pending OIRA review: Proposed regulations under section 245A
Nov 4, 2018 - KPMG report: Initial impressions of proposed regulations coordinating sections 956 and 245A
Nov 1, 2018 - Proposed regulations under section 956, released to Federal Register
Oct 31, 2018 - Proposed regulations: Amount determined under section 956 for corporate U.S. shareholders (text of regulations)