U.S. IRS Releases Revised Practice Unit on the Receipt of Dividends or Interest from a Related CFC

The U.S. IRS has released a revised international practice unit on the Receipt of Dividends or Interest from a Related CFC. The practice unit was revised to include the extension of the IRC 954(c)(6) look through rule for CFCs with tax years beginning before 1 January 2021 as part of the Taxpayer Certainty and Disaster Tax Relief Act of 2019. The practice Unit supersedes the unit of the same title released in 2016.

The general overview of the revised practice unit is provided as follows:

G…