Notice 2005-64, Foreign Tax Credit

and Other Guidance Under Section 965, 2005-36 IRB 471 (9-6-2005). This notice provides guidance on the one-time dividends received deduction under former § 965 for certain cash dividends from controlled foreign corporations that are invested in the United States, foreign tax credit and related issues, foreign currency translation, the alternative minimum tax, and the credit for prior year minimum tax.

.05 The following guidance relates to a topic now squarely addressed by amendments made to the Code by Public Law 115-97, 131 Stat. 2054 (December 22,

1 Unless otherwise specified, all “Section” or “§” references are to sections of the Code or the Income Tax Regulations (26 CFR part 1).

Bulletin No. 2025–19 1427 May 5, 2025

2017), commonly known as the Tax Cuts and Jobs Act.