§ 245A and T.D. 9865: Two Steps Forward, One Step Back for Temporary Treasury Regulations?

5 Pages Posted: 4 Feb 2020

See all articles by Kristin E. Hickman

Kristin E. Hickman

University of Minnesota - Twin Cities - School of Law

Date Written: January 10, 2020

Abstract

This "prompt" for the Columbia Journal of Tax Law's "Tax Matters" online publication analyzes the Treasury Department's assertion of the good cause exception when it issued temporary Treasury regulations without notice and comment under the new IRC § 245A, enacted as part of the Tax Cuts and Jobs Act to provide a dividends received deduction for U.S. corporations receiving dividends from certain non-U.S. subsidiaries.

Keywords: tax, TCJA, 245A, dividends received deduction, good cause exception, Administrative Procedure Act, temporary regulations

JEL Classification: K23, K34

Suggested Citation

Hickman, Kristin E., § 245A and T.D. 9865: Two Steps Forward, One Step Back for Temporary Treasury Regulations? (January 10, 2020). Columbia Journal of Tax Law, Forthcoming, Available at SSRN: https://ssrn.com/abstract=3517322 or http://dx.doi.org/10.2139/ssrn.3517322

Kristin E. Hickman (Contact Author)

University of Minnesota - Twin Cities - School of Law ( email )

229 19th Avenue South
Minneapolis, MN 55455
United States
612-624-2915 (Phone)

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