What is the Tax Cuts and Jobs Act 2017 and what does it have

What is the Tax Cuts and Jobs Act 2017, and what does it have to due with Internal Revenue Code Sections 243 and 245?

Solution

Tax Cuts and Jobs Act would make modifications to the Internal Revenue Code. It includes a much lower corporate tax rate, changes to credits and deductions & a move to a territorial system for corporations that have overseas earnings.

Any gain on the sale or exchange of stock in a foreign corporation held for more than one year recognized by domestic coporation is treated as a dividend under Section 1248. Dividend is to be interpreted consistent with Sections 243 and 245. So, dividends received from a foreign corporation by a domestic corporation through a partnership that would be eligible for the 100% deduction and if the domestic corporation owned the stock of the foreign corporation directly, that also eligible for the 100% deduction.