Results.

(ii) Results. Although the dividend received by USS1 from USS2 is excluded from USS1's income for purposes of determining the U.S. Federal income tax liability of the affiliated group of which USS1 and USS2 are members, pursuant to paragraph (b)(1) of this section, for purposes of section 1297, USS1's gross income includes the USS2 dividend. Accordingly, for purposes of section 1297, TFC's gross income includes 25% of the dividend received by USS1 from USS2 pursuant to section 1297(c) and 1.1297-2(b)(2)(ii). See section 1298(b)(7) and 1.1298-4 for rules concerning the characterization of the USS2 dividend.

Source

26 CFR § 1.1297-1


Scoping language

None
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