The regulation finalizes the rule providing that section 301(c)(3) distributions from a foreign corporation are subject to dividend recharacterization under section 1248(a).
Click the 'X' in the top right corner to close this window.
Contacts
- Doug McHoney
- International Tax Outbound Services co-leader
- Tel: +1 (513) 361 8165
- Michael Urse
- International Tax Outbound Services co-leader
- Tel: +1 (216) 875 3358
- Email ITS
