Inter-corporate dividend deduction limits relief to received dividends matched by prior distributions and forbids duplicate claims. A domestic company may deduct dividend income received from another domestic company, a foreign company, or a business trust, to the extent that such dividend income does not exceed the amount of dividend the domestic company distributed at least one month before the due date for filing its return under section 263(1); once a deduction for a distributed amount is allowed in one tax year, that amount cannot be deducted in any other tax year.
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Provisions expressly mentioned in the judgment/order text.
Inter-corporate dividend deduction limits relief to received dividends matched by prior distributions and forbids duplicate claims.
A domestic company may deduct dividend income received from another domestic company, a foreign company, or a business trust, to the extent that such dividend income does not exceed the amount of dividend the domestic company distributed at least one month before the due date for filing its return under section 263(1); once a deduction for a distributed amount is allowed in one tax year, that amount cannot be deducted in any other tax year.
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