Treasury Defends Dividend Deduction Rules as ‘Narrowly Tailored’ (1)

Treasury is standing by its position that 2019 temporary regulations for a business deduction don’t violate the Administrative Procedure Act.

The department defended its position in final rules released Friday (T.D. 9909; RIN: 1545-BP35) on the Section 245A dividends-received deduction. Section 245A limits the deduction a U.S.-based company can receive for dividends acquired from a foreign company in which it holds at least a 10% stake.

The Administrative Procedure Act governs the rule-making process and requires federal agencies to give notice and respond to significant comments for certain rules.

The U.S. Council of International Business ...