Dividend income from foreign subsidiaries of a U.S. S corporation

The recent IRS guidance in Chief Counsel Advice (CCA) 201030024 for U.S. S corporations earning dividends from foreign subsidiaries and those with Subpart F income, while not precedent, is welcome guidance and provides a good roadmap for those needing to analyze the issues surrounding passive investment income (too much of which is a big no-no) for S Corporations.  For complete text see here: http://www.irs.gov/pub/irs-wd/1030024.pdf

Anticipated Provisions of the Tax Relief Act of 2010

IRS reorganizes to focus on international tax administration