Andersen Managing Directors Joe Calianno and Sean Dokko’s article IRS Slams the Door on Section 245A DRDs for CFCs – But Is the Door Truly Shut? is featured in the latest issue of the Journal of Corporate Taxation (WG&L). In the article, Joe and Sean examine an Internal Revenue Service (IRS) Office of Chief Counsel Memorandum (CCA), in which IRS determined that a controlled foreign corporation (CFC) is ineligible for a Section 245A dividends received deduction. Joe and Sean conclude that, given the differing interpretations of the legislative history, statutory, and regulatory language regarding Sec. 245A and CFCs, it appears likely that some taxpayers may take a contrary position to the CCA, setting the stage for further disputes or litigation.