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PTI |
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Cash distributions eligible for the section 965 DRD may be received from entities other than the CFC that paid a qualifying cash dividend; namely, disregarded entities, partnerships, and CFCs that, pursuant to Code [section] 965(a)(2), distribute as previously taxed income dividends received from a lower tier CFC. Exchange gain or loss: While a distribution of previously taxed income (PTI) is not taxed again, it can result in foreign currency gain or loss under Sec. Therefore, to tax dividends at any level is to tax previously taxed income. |
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