Andersen Managing Director Joe Calianno comments are featured in the recent Tax Notes article, Foreign Dividend to CFC Ineligible for Dividend Deduction. The article covers a legal memorandum (ILM 202436010) released by IRS finding that lower-tier dividends from a specified foreign corporation to a controlled foreign corporation (CFC) are ineligible for the dividends-received deduction (DRD). Joe noted that this is the first time that IRS is going through the various arguments supporting the DRD under Sec. 245A and concluding that such arguments, in IRS's view, do not support the CFC being eligible for the Sec. 245A DRD. He added that the footnote in the legislative history seems to support that Congress intended for a CFC to be eligible for the Sec. 245A DRD.