Alan Greenspan is an American economist who served as the 13th chairman of the U.S. Federal Reserve from 1987 to 2006. He is known to have authored the following quote: “I know you think you understand what you thought I said but I’m not sure you realize that what you heard is not what I meant.” This statement epitomizes the conflict between the I.R.S. and various taxpayers regarding the application of Code §245A to the computation of C.F.C. income for purposes of Subpart F. Code §245A allows a domestic corporation to reduce taxable income by means of a dividends received deduction (“D.R.D.”) for the foreign-source portion of a dividend received by a U.S. corporation from a ≥10%-owned foreign corporation. Treas. Reg. §1.952-2 requires that a C.F.C. must calculate its income for U.S. income tax purposes by using U.S. rules as though it were a domestic corporation. Finally, Code §245A(e)(2) expressly provides a rule for C.F.C.’s receiving hybrid dividends from a lower-tier subsidiary. The D.R.D. is expressly disallowed at the level of a C.F.C. receiving the hybrid dividend. Nonetheless, in C.C.A. 202436010, the I.R.S. enunciated its view that a C.F.C. could not claim a benefit from the D.R.D. Rather, the benefit is first claimed by a domestic corporation when it recognizes income. So, which position is correct? In his article, Wooyoung Lee discusses the law, the regulations, the C.C.A., and cases addressing the deference that should be given by courts to the views of an administrative agency when evaluating the interpretation of a statute.