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Regulations limiting the availability of the dividends received deduction under section 245A and the exclusion from subpart F income under section 954(c)(6) for certain distributions of earnings and profits generated in transactions that avoided taxation under international tax rules in sections 965, 951, and 951A. The regulations apply to transactions taking place after section 965 applied but before section 951A applied (extraordinary dispositions), and to transactions that use section 951(a)(2)(B) to avoid tax in the context of a change in ownership of a CFC (extraordinary reductions). These temporary regulations were published alongside an identical companion notice of proposed rulemaking that became TD 9909, RIN 1545-BP35.