Subpart F income and DRD – REG clarification

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    Topic
  • #2579079
    KeepPushing
    Participant

    In becker’s R5 M6 page 59 it states that a US corp can deduct 100% of dividends received from a foreign corp if the US corp owns 10% or more of that foreign corp’s stock. However, on page 60 it states that a US corp receiving subpart F income ( which includes the income received from a foreign corp that is owned 10% or more by a US entity ) will no be eligible for 100% of DRD. Then it talks about dates, does this mean that IF the entity began after 12/31/17 then and ONLY then they can deduct 100 of those dividends? if US entity began BEFORE that date, then it is subject to taxation?? confused. thanks in advance.

Viewing 4 replies - 1 through 4 (of 4 total)
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  • #2579319
    Desmond
    Participant

    How much weightage do you think these two modules (M5-6) of R5 have coz i am thinking of leaving these 😭

    #2579535
    KeepPushing
    Participant

    The AICPA Reg blueprint has the Multi-jurisdictional tax issues under the taxation of entities which can be up to 38% of the exam. So sadly, I think I should be able to at least have an understanding of the information. If you look at the blueprint related to this topic, most, except for 3 items that are listed under “application”, are under the “remembering and understanding column” so I'd like to like I said at least understand the basic definitions. Even though it is a hard topic for me in particular to try and grasp so I am trying my best.

    #2579601
    Desmond
    Participant

    I checked out those pages/lines you referred above. As per my understanding, you are correct, for years 2017 and prior, dividends RECEIVED are taxed and for 2018 and forward 100% DRD can be taken by corporations (on both page 59 and 60 they mention that 100% DRD is applicable for years starting after 12.31.17)

    #2579856
    KeepPushing
    Participant

    I truly appreciate it!! I looked over the date on page 59. Sometimes you read this big book 20 times and on the 21st time you still see something new LOL

Viewing 4 replies - 1 through 4 (of 4 total)
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