Dividends

News & Analysis as of

Minimizing Tax on Gain from the Sale of Stock of Latin American CFCs

The United States currently has only two income tax treaties in effect with Latin American jurisdictions: Mexico and Venezuela. As a result, most individual taxpayers who recognize gain from the sale of stock of a controlled...more

Court of Appeal considers the treatment of contingent assets in balance sheet test

Evans v Jones [2016] EWCA Civ 660 - Executive Summary - The Court of Appeal recently considered an appeal from the liquidators of a property development company which went into creditors’ voluntary liquidation. The...more

Cancellation of CFC Loans to US Shareholders – Should the Service Get a Second Bite at the Apple?

The Service generally has three years after a return is filed to assess any tax due for that year. There are a number of exceptions to this general rule, such as where a taxpayer files a false return or omits more than 25...more

Your daily dose of financial news - The Brief – 8.19.16

The Journal reports that big companies [banks included] are pouring more into dividends than at “any time since the financial crisis”—likely, a response to record-low bond yields that’s “put a premium” on kicking back...more

Anatomy of a Term Sheet: Series A Financing (Q2 2016)

A key milestone in the lifecycle of many successful companies (and, admittedly, many unsuccessful companies) is obtaining financing from angel or venture capital investors, but in negotiating with experienced investors...more

Proposed QI Agreement Addresses Cascading Withholding on Dividend Equivalents

On July 1, the U.S. Internal Revenue Service issued Notice 2016-42, which proposes changes to the qualified intermediary (QI) agreement to address cascading U.S. withholding tax on dividends and “dividend equivalents”...more

Brexit – The UK and International Tax Consequences

The political, economic and constitutional fallout of the UK’s referendum decision to leave the European Union (Brexit) will continue for some time. In addition to considering some of the possible domestic UK tax implications...more

Withholding Agents–Obligation to Withhold On Payments to Foreign Persons When Source of Payment Uncertain

In recent guidance to auditors, the IRS discusses what happens when a payor withholding agent pays items to a foreign payee when the withholding agent is uncertain whether the payment is U.S. source....more

Just How Is Basis Acquired After All?

Dorrance v. U.S., 2015 WL 8241954 (9th Cir. 2015) - This case is the latest in the cases involving tax impact of the sale of stock received by a policy holder from a mutual life insurance company on demutualization, and...more

NBU gradually lifts “anti-crisis” restrictions (Ukrainian)

On 7 June 2016 the Board of the National Bank of Ukraine (NBU) adopted a new “anti-crisis” Resolution No. 342 (the Resolution.) The Resolution was adopted to replace the earlier “anti-crisis” Resolution of the NBU No....more

NBU gradually lifts “anti-crisis” restrictions

On 7 June 2016 the Board of the National Bank of Ukraine (NBU) adopted a new “anti-crisis” Resolution No. 342 (the Resolution.) The Resolution was adopted to replace the earlier “anti-crisis” Resolution of the NBU No....more

On Procedure of payment of dividends by a joint stock company

On 27 March 2016, the Securities and Stock Market State Commission (SSMSC) decision from 12 March 2016 of No. 391 “On Procedure of payment of dividends by a joint stock company” came into force....more

On Procedure of payment of dividends by a joint stock company (Ukrainian)

On 27 March 2016, the Securities and Stock Market State Commission (SSMSC) decision from 12 March 2016 of No. 391 “On Procedure of payment of dividends by a joint stock company” came into force. (Ukranian-only version)...more

Vanishing premiums part deux?

Those of you with gray hair like me may recall the life insurance vanishing premium lawsuits from the mid-1990s. As a refresher, that flood of lawsuits arose from life insurance policies sold in the 80s (mainly whole or...more

Potential tax consequences of Brexit from a German perspective

On 23 June, the UK is holding a referendum to decide whether it should leave or remain in the European Union. A vote to leave the EU (the so-called Brexit) would not only have repercussions from a tax perspective for the UK....more

Amendments to Dividend / Distribution Reinvestment Plans Regime

On April 28, 2016, The Toronto Stock Exchange (the “TSX”) published proposed amendments (the “Amendments”) to introduce requirements regarding Dividend / Distribution Reinvestment Plans (the “DRIPs”) to Part VI of the TSX...more

Your daily dose of financial news The Brief – 5.10.16

Big news out of the online lending space, as Lending Club’s chair and CEO—Renaud Laplanche—has resigned after an internal review “showed a violation of the company’s business practices” related to sales of $22 million in...more

Pennsylvania Audits Public Companies for Unclaimed Securities

Holders that use third-party transfer agents, such as Computershare, should check their mailboxes, as they are likely to have a notice from Pennsylvania of an unclaimed property audit. Pennsylvania has engaged...more

Why Delaware Corporations Should Worry About California Law When Making Dividends

When paying a dividend to shareholders, California corporations are subject to Chapter 5 of the California Corporations Code. Corporations incorporated in Delaware and other states may also be subject to Chapter 5 if they...more

Burr Alert: Is Tennessee "Retiring" Its Hall Income Tax?

Tennessee has long been known as a retirement friendly state and usually ranks in the Top 10 of any list identifying the best places in the U.S. for retirement. That reputation is about to be enhanced as Tennessee's...more

Is Your Corporation “Zeroing Out” Income at End of Year Through Bonuses? Watch Out!

For the last few years the IRS has warned taxpayers that it would look closely at year-end bonuses that resulted in “zeroing out” taxable income of a corporation by deducting the bonuses as salary rather than a payment of...more

IRS Proposes Updates to Rules for Deemed Distributions of Stock and Stock Rights

On April 13, 2016, the U.S. Department of the Treasury issued proposed regulations under Section 305(c) of the Internal Revenue Code that would resolve certain issues relating to the amount and timing of deemed distributions...more

Treasury Issues Stringent Inversion Regulations, Proposes Far-Reaching Related-Party Debt Rules

New regulations expand prior guidance reducing tax benefits of inversions. Proposed debt-equity rules will impact even routine intercompany transactions. On April 4, 2016, the US Department of the Treasury (Treasury) and...more

Treasury Targets Related-Party Debt with Proposed Regulations to Treat Debt as Equity

Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt. On April 4, 2016, the US Department of the Treasury (Treasury) and the...more

Should Professional Corporations Consider Making an S Corporation Election – Again?

The United States Tax Court has held that a law firm organized as a professional corporation is liable for accuracy-related penalties for treating year-end bonuses to the shareholder attorneys as compensation (deductible)...more

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