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Layla Asali Comments on Section 245A Regulations in Tax Notes

"IRS Hints at Technical Side of Future DRD Regs"

Tax Notes

Layla Asali commented on questions regarding how to apply section 245A when a specified foreign corporation (SFC) is owned through a partnership. At the January 2020 District of Columbia Bar tax conference, Asali discussed the application of the section 245A holding period rules to a SFC held through a foreign partnership with Logan Kincheloe, an attorney in the IRS Office of Associate Chief Counsel.