Page 163 - International Taxation IRS Training Guides

Participation Exemption (Cont’d)

 No deemed paid foreign tax credit
or deduction for

with respect
foreign taxes paid or accrued by the CFC
E&P for which the DRD is allowed
to

 DRD
not available for hybrid dividends

a CFC for which the CFC received a
• Amount received from
benefit related to taxes imposed by a foreign
deduction or other tax
country

• Dividend from lower-tier
CFC to upper-tier CFC is treated as subpart
F income

18