Page 227 - International Taxation IRS Training Guides

Dividends from

Surrogate Foreign Corporation

 Dividends
to individuals from domestic corporations

and certain foreign corporations receive a preferential

IRC 1(h)(11)
tax rate under

 TCJA amended new
IRC 1(h)(11)(C) to provide that

dividends
from surrogate foreign corporations are not
eligible for the preferential
tax rate

 Effective for dividends
received after Dec. 22, 2017

to corporations that first become
with respect
surrogate foreign corporations
after Dec. 22, 2017

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