§14101
5 cases·2 overruled·3 cited
Statute Text — 26 U.S.C. §14101
Statute text not available for this section.
5 Citing Cases
2054, 2189 (2017), provides a deduction (DRD) for certain dividends received by a U.S. corporation from certain foreign corporations. Given its formulation, the DRD had the potential to interact with existing I.R.C. § 78. As in effect before the TCJA, I.R.C. § 78 provided that, for taxpayers who claimed foreign tax credits, a spe
14101 et seq., 131 Stat. at 2189, which had an effective date for foreign corporations with taxable years beginning after December 31, 2017, and applies to tax years ofU.S. shareholders in which or with which such tax years offoreign corporations end. - 19 - A taxpayer's FBCSI is determined under section 954(d), reduced by deductions allowabl
14101 et seq., 131 Stat. at 2189, which had an effective date for foreign corporations with taxable years beginning after December 31, 2017, and applies to tax years ofU.S. shareholders in which or with which such tax years offoreign corporations end. - 19 - A taxpayer's FBCSI is determined under section 954(d), reduced by deductions allowabl