26 CFR §1.245A-10

1. (a)Scope. This section provides examples illustrating the application of §§ 1.245A-6 through 1.245A-9.
2. (b)Presumed facts. For purposes of the examples in the section, except as otherwise stated, the following facts are presumed:
   1. (1)US1 and US2 are both domestic corporations that have calendar taxable years.
   2. (2)CFC1, CFC2, CFC3, and CFC4 are all SFCs and CFCs that have taxable years ending November 30.
   3. (3)Each entity uses the U.S. dollar as its functional currency.
   4. (4)There are no items of deduction or loss attributable to an item of specified property.
   5. (5)Absent the application of § 1.245A-5, any dividends received by US1 from CFC1 would meet the requirements to qualify for the section 245A deduction.
   6. (6)All dispositions of items of specified property by an SFC during a disqualified period of the SFC to a related party give rise to an extraordinary disposition.
   7. (7)None of the CFCs have a deficit subject to § 1.381(c)(2)-1(a)(5), and none of the CFCs are engaged in the conduct of a trade or business in the United States (and therefore none of the CFCs have ECTI).
   8. (8)There is no previously taxed earnings and profits account with respect to any CFC for purposes of section 959. In addition, each hybrid deduction account with respect to a share of stock of a CFC has a zero balance at all times. Further, there is no extraordinary disposition account with respect to any CFC.
   9. (9)Under § 1.245A-11(b), taxpayers choose to apply §§ 1.245A-6 through 1.245A-11 to the relevant taxable years.