The 7% Solution: Structured Dividend Received Deduction Transactions Face Internal Revenue Service Audit Scrutiny
5 June 2013
Mayer Brown Legal Update
The Internal Revenue Service has released three separate pieces of audit guidance that challenge the right of corporate taxpayers to claim dividend received deductions in various transactions. The guidance seems directed at preventing the 7 percent effective corporate tax rate that results from the deductions in Section 243(c)(1) of the Internal Revenue Code of 1986, as amended.