EXHIBIT 16-6 Stock Ownership and Dividends Received Deduction Percentage
Receiving Corporation’s Stock Ownership in Distributing Corporation’s Stock
Dividends Received Deduction Percentage
Less than 20 percent
50%
At least 20 percent but less than 80 percent
65
80 percent or more*
100
* To qualify for the 100 percent dividends received, the receiving and distributing corporations must be in the same affiliated group as described in §1504. The 80 percent ownership requirement is the minimum ownership level required for inclusion in the same affiliated group.