Dividend-Deduction Rules Can’t be Retroactive, Group Says

Treasury is violating notice-and-comment requirements by making rules for limitations on dividends-received deductions retroactive, the United States Council for International Business said.

Proposed and temporary regulations under tax code Section 245A became immediately effective when they came out in June and apply to distributions after Dec. 31, 2017. The Internal Revenue Service should have followed the process of issuing a notice and 30-day effective date because the rules didn’t warrant an exception, USCIB said in a letter released Sept. 10. The USCIB is a business advocacy group representing about 300 multinationals, law firms, and business associations.

• The rules provide ...