In this article, Jeffrey Tebbs and Caroline Reaves critically analyze a controversial Advice Memorandum from the IRS Office of Associate Chief Counsel (International), which concluded that section 245A does not allow a deduction for a dividend received by a controlled foreign corporation (CFC) from a "specified 10-percent owned foreign corporation." Tebbs and Reaves contend that the operative question is not whether a CFC should be allowed a section 245A deduction, but instead whether the subpart F income of the CFC should be computed by treating the CFC as a domestic corporation for which the deduction may be available. By framing the question incorrectly, the Advice Memorandum reaches conclusions that defy longstanding regulations under subpart F, producing outcomes that cannot be reconciled with express statements of Congressional intent. The authors encourage the Treasury Department to restart the guidance projects that were first proposed in 2018 to address the interaction of subpart F with the quasi-territorial system created by the Tax Cuts and Jobs Act of 2017.