100% DRD for CFC Dividends

Overview


Lowell Yoder wrote a bylined article discussing the 100% dividends received deduction that is available for dividends received from CFCs beginning in 2018. The DRD is also available for other amounts that are treated as a dividend for tax purposes, such as dividend-equivalent redemption distributions and gain on the sale of stock in a CFC that is re-characterized as a dividend under section 1248. This article also highlights several issues to be addressed by regulations.