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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.
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