US Codex
U.S.C.
Notes

§245A. Deduction for foreign source-portion of dividends received by domestic corporations from specified 10-percent owned foreign corporations — Inbound Citations

26 U.S.C. § 245A

Cited by 14 provisions in release 119-102.

Citations to 26 U.S.C. § 245A as a whole

  • 26 U.S.C. § 59A(c)(4)(B)(i)
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    (i) any deduction allowed under section 172, 245A, or 250 for the taxable year,
  • 26 U.S.C. § 78
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    If a domestic corporation chooses to have the benefits of subpart A of part III of subchapter N (relating to foreign tax credit) for any taxable year, an amount equal to the taxes deemed to be paid by such corporation under subsections (a) and (d) of section 960 (determined without regard to the phrase “90 percent of” in subsection (d)(1) thereof) for such taxable year shall be treated for purposes of this title (other than sections 245 and 245A) as a dividend received by such domestic corporation from the foreign corporation.
  • 26 U.S.C. § 91(a)
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    (a) If a domestic corporation transfers substantially all of the assets of a foreign branch (within the meaning of section 367(a)(3)(C), as in effect before the date of the enactment of the Tax Cuts and Jobs Act) to a specified 10-percent owned foreign corporation (as defined in section 245A) with respect to which it is a United States shareholder after such transfer, such domestic corporation shall include in gross income for the taxable year which includes such transfer an amount equal to the transferred loss amount with respect to such transfer.
  • 26 U.S.C. § 246(c)(5)(A)
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    (A) For purposes of section 245A—
    (i) paragraph (1)(A) shall be applied—
    (I) by substituting “365 days” for “45 days” each place it appears, and
    (II) by substituting “731-day period” for “91-day period”, and
    (ii) paragraph (2) shall not apply.
  • 26 U.S.C. § 246(c)(5)(B)
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    (B) For purposes of applying paragraph (1) with respect to section 245A, the taxpayer shall be treated as holding the stock referred to in paragraph (1) for any period only if—
    (i) the specified 10-percent owned foreign corporation referred to in section 245A(a) is a specified 10-percent owned foreign corporation at all times during such period, and
    (ii) the taxpayer is a United States shareholder with respect to such specified 10-percent owned foreign corporation at all times during such period.
  • 26 U.S.C. § 904(b)(4)(B)
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    (B) any deductions properly allocable or apportioned to—
    (i) income (other than amounts includible under section 951(a)(1) or 951A(a)) with respect to stock of such specified 10-percent owned foreign corporation, or
    (ii) such stock to the extent income with respect to such stock is other than amounts includible under section 951(a)(1) or 951A(a).
    Any term which is used in section 245A and in this paragraph shall have the same meaning for purposes of this paragraph as when used in such section.
  • 26 U.S.C. § 961(d)
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    (d) If a domestic corporation received a dividend from a specified 10-percent owned foreign corporation (as defined in section 245A) in any taxable year, solely for purposes of determining loss on any disposition of stock of such foreign corporation in such taxable year or any subsequent taxable year, the basis of such domestic corporation in such stock shall be reduced (but not below zero) by the amount of any deduction allowable to such domestic corporation under section 245A with respect to such stock except to the extent such basis was reduced under section 1059 by reason of a dividend for which such a deduction was allowable.
  • 26 U.S.C. § 6039E(d)
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    (d) Notwithstanding any other provision of law, any agency of the United States which collects (or is required to collect) the statement under subsection (a) shall—
    (1) provide any such statement to the Secretary, and
    (2) provide to the Secretary the name (and any other identifying information) of any individual refusing to comply with the provisions of subsection (a).
    Nothing in the preceding sentence shall be construed to require the disclosure of information which is subject to section 245A of the Immigration and Nationality Act (as in effect on the date of the enactment of this sentence).

Citations to §245A(a)

Citations to §245A(b)

  • 26 U.S.C. § 904(d)(2)(E)(i)(I)
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    (I) a specified 10-percent owned foreign corporation (as defined in section 245A(b)), or
  • 26 U.S.C. § 909(b)
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    (b) If there is a foreign tax credit splitting event with respect to a foreign income tax paid or accrued by a specified 10-percent owned foreign corporation (as defined in section 245A(b) without regard to paragraph (2) thereof), such tax shall not be taken into account—
    (1) for purposes of section 960, or
    (2) for purposes of determining earnings and profits under section 964(a),
    before the taxable year in which the related income is taken into account under this chapter by such specified 10-percent owned foreign corporation or a domestic corporation which is a United States shareholder with respect to such specified 10-percent owned foreign corporation.

Citations to §245A(c)