News & Analysis as of

Dividends

Will New Spanish Dividend Rules Cause Pain for Private Equity in Spain?

by Latham & Watkins LLP on

Recently effected reforms to Spanish dividend protections for minority shareholders should cause European dealmakers to review deal terms more closely in 2017. Outright acquisition of businesses is unusual in Spain, 83% of...more

Fun with Roth IRAs: New Sixth Circuit Decision Blesses Aggressive Tax Planning

by Foley & Lardner LLP on

A recent decision by the Federal Sixth Circuit Court of Appeals expands the potential for Roth IRAs to be used to protect income from corporate and shareholder level tax....more

"Recent Court of Appeals Decision Provides Hope for Taxpayers Fighting for Congressionally Sanctioned Tax Benefits"

For the second time in just over a year, the U.S. Court of Appeals for the Sixth Circuit reversed the United States Tax Court and affirmed the right of a taxpayer to structure its affairs in a manner that takes into account...more

Budget 2017

by Hogan Lovells on

The 2017 Budget was presented by Minister Pravin Gordhan before Parliament on 22 February 2017. The 2017 tax proposals are projected to raise ZAR28 billion, and increase the tax burden from 26% of GDP in 2016/17 to 26.7%...more

Financial Services Weekly News - February 2017 #3

by Goodwin on

Editor's Note - A Not So New Tool for Reigning in Federal Regulations. President Trump has signed a Joint Resolution of Congress which “disapproves the rule submitted by the SEC relating to ‘Disclosure of Payments by...more

MoFo Tax Talk: Volume 9, Issue 4

by Morrison & Foerster LLP on

EDITOR’S NOTE - Tax Talk doesn’t remember much about 1985. But we do remember that, after Ronald Reagan was re-elected president in 1984, tax reform was a very hot topic (remember the Tax Reform Act of 1985?). Anyway,...more

Derivatives In Review - January 2017

Regulation AT – An Update - From the time Regulation AT was initially proposed by the CFTC over a year ago, the CFTC has solicited and considered numerous comment letters, held a public roundtable, supplemented the...more

Impact of Tax Reform Proposals on REITs and Real Estate

by Goodwin on

This alert focuses on various tax reform proposals and their potential impact on REITs and the real estate industry. Tax reform is high on the agendas of both the House Ways and Means Committee and the Trump administration....more

Employee Benefits Legislation Proposed (But Not Passed) by the Obama Administration

by Jackson Walker on

In February of 2015, the Department of Treasury issued a reported entitled “General Explanation of the Administration’s Fiscal Year 2016 Revenue Proposals” (the “General Explanation”). The General Explanation is several...more

2016 half-year in review: M&A legal developments

by White & Case LLP on

We set out below a number of interesting English court decisions and market developments which have taken place and their impact on M&A transactions. This review looks at these developments and gives practical guidance on...more

IRS Reduces Built-in Gains Tax Period for REITs to Five Years

One of the key benefits of a real estate investment trust (“REIT”) is that it is effectively a pass through entity for income tax purposes. While a REIT pays tax on its taxable income, it also receives a dividends paid...more

When Investing In A Partnership May Be A Tax Problem

by Farrell Fritz, P.C. on

A business entity that is treated as a “flow-through” for income tax purposes enjoys the benefit of a single level of tax – the entity itself is typically not subject to tax on its net income; rather, that income “flows...more

When insurance pays dividends….. Distribution of long-term insurance profits

by Hogan Lovells on

On 30 December 2016, the Companies Act 2006 (Distributions of Insurance Companies) Regulations 2016 (the “Regulations“) came into force. The Regulations apply to distributions made on or after that date by reference to...more

European Central Bank Publishes Outcome of Supervisory Review and 2017 Recommendations on Dividends and Variable Remuneration

by Shearman & Sterling LLP on

The European Central Bank published the outcome of its second Supervisory Review and Evaluation Process in 2016 and updated Recommendations on dividend distribution and remuneration policies for 2017. The ECB comments that...more

Stock Dividend Foot Faults

by Alston & Bird on

Recently the Treasury issued proposed regulations for Section 305. The proposal was prompted by Section 6045B, enacted in 2008 and effective only under regulations requiring the issuer of stock to provide basis reporting. A...more

A Sharpening of the Pensions Regulator's Claws

by White & Case LLP on

The Pensions Regulator ("TPR") has wide-ranging statutory powers to intervene in the running of work-based pension schemes. The most prominent of these are the so-called "moral hazard powers". To date, TPR has used these...more

IRS Releases Transition Guidance for the Dividend Equivalent Rules

On December 2, 2016, the Internal Revenue Service (the “IRS”) issued Notice 2016-76 (the “Notice”), which provides highly anticipated guidance regarding “dividend equivalent” payments under section 871(m) of the Internal...more

Much-Anticipated Section 871(m) Dividend Equivalent Guidance Provides Promised Transition Relief

by Dechert LLP on

The U.S. Internal Revenue Service (the “IRS”) has released Notice 2016-76, providing anticipated guidance and transition relief for certain dividend equivalent transactions described in section 871(m) of the U.S. Internal...more

IRS Guidance for Implementation of the Section 871(m) Regulations

by Morrison & Foerster LLP on

On December 2, 2016, the Internal Revenue Service (“IRS”) released an advance version of Notice 2016-76 (the “Notice”) and followed through on its promise to provide taxpayers with guidance for complying with final and...more

IRS Phases in Section 871(m) Dividend Equivalent Withholding

On December 2, the U.S. Internal Revenue Service issued Notice 2016-76, which phases in the application of withholding on dividend equivalent payments under section 871(m). Under the notice, withholding applies only to...more

ISS and Glass Lewis Update Their Proxy Voting Guidelines for 2017

by Morrison & Foerster LLP on

Institutional Shareholder Services Inc. (“ISS”) and Glass, Lewis & Co., LLC (“Glass Lewis”) recently updated the guidelines they will use to inform their voting recommendations for the 2017 proxy season. The updates address...more

Development of Russian court practice on tax implications when dividends are paid to foreign companies (application of the...

by Dentons on

On 13 October 2016 the Commercial Court of Kemerovo Region delivered a judgement in case No. ?27-20527/2015 (the “Decision”) under the claim of Krasnobrodsky Yuzhny Limited Liability Company (the “Company”)....more

Mississippi Supreme Court Finally Disconnects The Line On Dividend Exclusion Statute In The AT&T Case

by Butler Snow LLP on

In a previous article, we summarized AT&T’s 16-year effort, in two separate lawsuits, to have declared unconstitutional two Mississippi income tax statutes on the alleged basis that they placed a greater tax burden on AT&T...more

Renewed Perils from “Zeroing Out” a Corporation at Year-End

by Dickinson Wright on

Physicians who are involved in the financial management of their practices are all too familiar with the year-end scramble to “zero out” the corporation’s profits. Under this technique, a physician practice that is structured...more

Section 871(m) Dividend Equivalent Guidance Including New Transition Relief Expected After Mid-November

by Dechert LLP on

The U.S. Internal Revenue Service (the “IRS”) plans to release a guidance package including final rules and transition relief for dividend equivalent transactions described in Section 871(m) of the U.S. Internal Revenue Code...more

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