About the Course
Introduction
This CPE webinar will examine the requirements of the Section 245A dividends-received deduction (DRD) for foreign-source dividends received by domestic corporations from specified 10%-owned foreign corporations. Our panel of knowledgeable advisers will discuss qualification requirements, calculating the deduction, recent court decisions, and the effect of new pro rata share rules on 245A planning.
Description
In order to claim the 100% DRD, the recipient must be a domestic C corporation owning at least 10% of a foreign corporation by vote or value, satisfy the more-than-365-day holding period requirement, and determine the foreign-source portion of the dividend for the 245A deduction.
Recent legislative and regulatory developments have further elevated the importance of Section 245A planning. Among the most significant changes are the One Big Beautiful Bill Act's new pro rata share rules, which replace the last-day rule with a period-of-ownership method for allocating Subpart F income and Net CFC Tested Income (NCTI), along with recently released regulations providing guidance for these determinations. These changes may substantially affect transactions involving CFC and require taxpayers and their advisers to reassess planning assumptions and compliance procedures.
Listen as our accomplished panel explains the requirements and limitations of the Section 245A dividends received deduction, discusses recent statutory, regulatory, and judicial developments, and provides practical guidance on planning opportunities, compliance obligations, and the new pro rata share rules for U.S. shareholders of CFCs.
Presented By
Mr. Gbegnon is a partner in the International Tax Services practice at PwC’s Silicon Valley office (San Jose). His practice focuses on tax planning for cross-border M&A and restructurings, IP integration, taxation of online/digital transactions and tax attribute planning (including foreign tax credits). Mr. Gbegnon is a member of the California Bar Association.
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BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
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BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
Date + Time
- event
Friday, December 18, 2026
- schedule
1:00 PM ET/10:00 AM PT
I. Overview of the Section 245A DRD
II. Qualification requirements for Section 245A DRD
III. Computing and claiming the deduction
IV. Exclusions and anti-abuse rules
V. Recent developments
VI. New pro rata share rules
VII. IRS proposed regulations
VIII. Examples: Section 245A in common cross-border transactions
IX. Planning opportunities and compliance challenges
The panel will review these and other key issues:
- Eligibility requirements for the Section 245A DRD
- Holding period requirements
- Calculating the foreign-source portion of a dividend
- Implementing the new pro rata share rules
Learning Objectives
After completing this webinar you will be able to:
- Ascertain eligibility requirements for the Section 245A DRD
- Decide how the dividends received deduction is calculated
- Determine how the new pro rata share rules allocate Subpart F income and NCTI among U.S. shareholders
- Identify the effects of ownership changes and stock transfers on inclusions and reporting
- Field of Study: Taxes
- Level of Knowledge: Intermediate
- Advance Preparation: None
- Teaching Method: Seminar/Lecture
- Delivery Method: Group-Internet (via computer)
- Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
- Prerequisite:
Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of international taxation, including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI/NCTI, Subpart F, and the related Section 250 deductions.
BARBRI, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.
BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
BARBRI CE webinars-powered by Barbri-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .
