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TREAS/IRS RIN: 1545-BP18 Publication ID: Fall 2024 
Title: Regulations Under Section 245A and Related Provisions 
Abstract:

The Tax Cuts and Jobs Act of 2017 added section 245A to provide a dividends received deduction to certain domestic corporations for dividends received from certain foreign corporations.  These proposed regulations will provide guidance as to what dividends are eligible for the section 245A dividends received deduction. In addition, the proposed regulations will provide rules for determining taxpayers’ eligibility for the dividends received deduction under section 245A and calculating the amount of the dividend received that is eligible for the dividends received deduction under section 245A.

 
Agency: Department of the Treasury(TREAS)  Priority: Substantive, Nonsignificant 
RIN Status: Previously published in the Unified Agenda Agenda Stage of Rulemaking: Proposed Rule Stage 
Major: No  Unfunded Mandates: No 
CFR Citation: 26 CFR 1   
Legal Authority: 26 U.S.C. 7805    26 U.S.C. 245A   
Legal Deadline:  None
Timetable:
Action Date FR Cite
NPRM  07/00/2025 
Additional Information: REG-111689-20 (NPRM) Drafter attorney: Elena Madaj (202) 317-3576 Reviewer attorney: Robert Williams (202) 317-6937 Treasury attorney: Brenda Zent (202) 622-6894 CC:INTL
Regulatory Flexibility Analysis Required: No  Government Levels Affected: None 
Small Entities Affected: No  Federalism: No 
Included in the Regulatory Plan: No 
RIN Data Printed in the FR: No 
Agency Contact:
Elena Madaj
Attorney
Department of the Treasury
Internal Revenue Service
1111 Constitution Avenue NW , Room 4579 ,
Washington, DC 20224
Phone:202 317-3576
Fax:855 589-8671
Email: elena.m.madaj@irscounsel.treas.gov