Tax Court: Section 951 Inclusions Not Qualified Dividend Income

The Tax Court, in a Division Opinion by Judge Thornton, determines that required inclusions in income from a controlled foreign corporation pursuant to Section 951 do not constitute qualified dividend income under Section 1(h)(11).

Regular observers of the Tax Court will note this opinion for its careful and persuasive discussion of statutory interpretation and legislative history to decide this issue.

Read the opinion here:
Rodriguez v. Commissioner, 137 T.C. No. 14 (2011)