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KPMG report: Regulations under sections 245A, 951A, 954 (GILTI); treatment of dividends from foreign corporations

KPMG report: Regulations under sections 245A, 951A, 954

Final regulations under sections 245A and 954(c)(6) and proposed regulations under sections 245A and 951A were published in the Federal Register on August 27, 2020.


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The final regulations finalize proposed regulations (2019) under sections 245A and 954(c)(6), and also withdraw temporary regulations that accompanied and served as the text of the 2019 proposed regulations.

Read a September 2020 report [PDF 439 KB] prepared by KPMG LLP that provides a description of the key provisions of the 2020 final and proposed regulations and includes key insights and observations.

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