Layla Asali Comments on Participation Exemption for Lower-Tier Dividends in Tax Notes

"IRS Not Yet Convinced of Lower-Tier DRD Applicability"

Tax Notes

03.09.2020

At the March 2020 Federal Bar Association Tax Law Conference, Asali discussed potential guidance on the section 245A dividends-received deduction (DRD) or participation exemption with Laura Williams, a Branch Chief in the IRS Office of Associate Chief Counsel (International). Asali and Williams exchanged views on the applicability of the DRD to dividends from lower-tier dividends.