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In particular, section 3 makes clear that taxpayers may not specifically identify qualifying dividends as either deductible or nondeductible in whole or in part.
Thus, prior to the 2004 Act, a CFC that was also a FPHC could not pay qualifying dividends, whereas a CFC that was also a PFIC, but not a FPHC could do so.
Section 302 of the Jobs and Growth Tax Relief Reconciliation Act of 2003 (JGTRRA) reduced the income tax rate for qualifying dividends received by individuals to 15% (5% for taxpayers in the 10% mid 15% tax brackets).