Page 697 - Large Business IRS Training Guides

Why Section 965 Exists:
Post-TCJA Law

FC generally receive 100%
• Dividends from

dividends received deduction (DRD)
under
section 245A

• No tax on repatriation

• Subpart F remains intact

• GILTI subjects certain non-subpart F foreign

income to tax

• Section 956 also remains in effect (but under

are now
regulations section 956 amounts

reduced to the extent the section
generally
245A DRD
would apply to a dividend)

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