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US Tax Court allows a domestic corporation to claim IRC Section 245A DRD for IRC Section 78 dividend on IRC Section 965 inclusion from fiscal-year CFCs but reduces FTC claim

|Tax Alerts, National/Federal Taxation, L ...|United States
United States

  • The Tax Court held that a portion of a company's 2017 mandatory repatriation tax inclusion under IRC Section 965 from a CFC with a non-calendar tax year is exempt from tax under IRC Section 245A.
  • However, the Court correspondingly held that a portion of that company's deemed-paid foreign income taxes are not creditable.
  • Taxpayers should evaluate (1) their opportunities to file protective or actual refund claims; and (2) the applicable statute of limitations and other elements of their tax controve…

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