IRS practice unit: Receipt of dividends or interest from a related CFC

IRS practice unit

The IRS Large Business and International (LB&I) division publicly released a “practice unit”—part of a series of IRS examiner “job aides” and training materials intended to describe for IRS agents leading practices about tax concepts in general and specific types of transactions.

1000

Related content

The title of this “transaction unit” (as referred to by the IRS) is: Receipt of dividends or interest from a related CFC

Read this transaction unit on the IRS practice unit webpage (posting date of March 29, 2021).

The practice unit was revised to include the extension of Code section 954(c)(6) look-through rule for controlled foreign corporations (CFCs) with tax years beginning before January 1, 2026. This extension was part of the “Consolidated Appropriations Act, 2021.” The practice unit supersedes two prior practice units (January 2016 and January 2020) with the same title.

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us

 

Want to do business with KPMG?

 

loading image Request for proposal