Page 650 - Large Business IRS Training Guides
P. 650
Anti-Abuse Rules
5
Sec. 965 Asset sale
meas. date
1/1/18 11/30/18 12/31/18 11/30/19 12/31/19
USP
CFC1 DISQUALIFIED PERIOD CFC1’s first inclusion year
CFC2 CFC2’s first inclusion year
245A
DRD
• Dividends-received-deduction under §245A: A dividend from CFC1 to
USP may qualify for §245A dividends-received-deduction (assuming
certain requirements are met).
66
