News & Analysis as of

Dividends Income Taxes

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

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

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

Brexit – The UK and International Tax Consequences

by Dechert LLP on

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

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

by Burr & Forman on

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

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

by Latham & Watkins LLP on

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

MoFo Tax Talk - Volume 8, No. 4

by Morrison & Foerster LLP on

IRS PROVIDES RICS ALTERNATIVES TO ACCOUNT FOR FOREIGN TAX REFUNDS - Generally, when a U.S. taxpayer pays foreign tax, the U.S. taxpayer is entitled to take a credit (a “Foreign Tax Credit”) against the taxpayer’s U.S....more

Congress Passes New Tax Laws Affecting REITs - Protecting Americans from Tax Hikes Act of 2015

by McGuireWoods LLP on

On December 18, President Obama signed the Protecting Americans from Tax Hikes (PATH) Act of 2015 (the “Act”) into law. The Act provides for a number of favorable and flexible REIT-specific tax provisions, and implements...more

MoFo New York Tax Insights - Volume 6, Issue 10

by Morrison & Foerster LLP on

State Tax Department Releases Draft Article 9-A Nexus Regulations Under Corporate Tax Reform - The New York State Department of Taxation and Finance has released draft amendments to the Article 9-A corporate franchise...more

Use of Estonia in U.S. International Tax Planning

According to recent estimates, Estonia, which is situated halfway between Stockholm and St. Petersburg, currently has more than 350 start-up technology companies – one for every 3,700 citizens – and the government expects...more

German Investment Taxation – Reform Ahead

by Dechert LLP on

The German Ministry of Finance (Bundesfinanzministerium) circulated a discussion draft bill on the reform of fund taxation (‘Draft Bill’) on 22 July 2015. The Draft Bill contains significant changes to the German tax...more

Focus on Tax Controversy - Summer 2015

by McDermott Will & Emery on

The French 3 Percent Distribution Tax: Claiming a Refund - Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but practitioners have widely...more

Guide To Doing Business in New Zealand: Taxation (Updated)

TAXATION - It is not possible to give a complete outline of the scope of the taxation system in this guide. A brief outline of the basic taxation principles and some of the major forms of taxation are discussed below....more

Tax Measures in the UK 2015 Summer Budget

by Morgan Lewis on

The new tax announcements are designed to improve productivity and correct imbalances in the tax system. On 8 July, UK Chancellor of the Exchequer George Osborne made a number of announcements relating to the tax system...more

UK Supreme Court case of Anson v. HMRC [2015] UKSC 44

by Proskauer Rose LLP on

Delaware LLC held to be UK tax transparent - The UK Supreme Court has handed down its judgment on the final appeal in the Anson case, in which it treated a taxpayer's interest in a Delaware LLC as transparent for UK tax...more

Latest actions of the Polish Ministry of Finance

by Dentons on

Recently the Polish Ministry of Finance has presented a new bill introducing amendments to the Tax Ordinance and proposed amendments to the income tax regulations....more

The Timing of E&P to US Parent Corporations of CFCs

by Charles (Chuck) Rubin on

The earnings and profits (E&P) of a corporation dictate the income tax treatment of non-liquidating distributions it makes to its shareholders. Distributions from a corporation to the extent of its current or accumulated E&P...more

Whose Mistake? Ontario Sup. Ct. Rectifies Trust Deed

by Dentons on

Most tax rectification cases address situations in which a professional advisor has made a mistake in the planning and execution of a transaction with the result that an unintended tax consequence follows (i.e., payment of a...more

IC-DISC Benefits Enhanced with Foreign Shareholders

Since the reduction in the individual tax rate on qualified dividends in 2004, the Interest Charge Domestic Sales Corporation (“IC-DISC”) has become an attractive vehicle to obtain a tax incentive for exporting U.S.-produced...more

IRS Signals a Potential End to Its Administrative Pursuit of the Separate Account DRD

On February 4, the IRS issued a new revenue ruling – Rev. Rul. 2014-7 – that indicates that the IRS no longer plans to issue formal guidance concerning the treatment of the dividends-received deduction (DRD) with respect to...more

Prop. Regs. Apply ‘Delta’ Approach For Dividend-Equivalent Payments To Foreign Persons

Section 871(m) was enacted in 2010 to curb the perceived abuse of foreign persons using derivatives — primarily notional principal contracts (NPCs) or swaps — to replicate the ownership of an underlying U.S. equity without...more

MoFo New York Tax Insights - Volume 6, No. 4 - January 2014

by Morrison & Foerster LLP on

In This Issue: FATCA Developments: Treasury Signs IGAs; IRS Finalizes FFI Agreement; IRS Releases Final and New Proposed “Dividend Equivalent” Regs; IRS Issues Final Swap Assignment Regs; IRS Issues Final “Net...more

Sale of dividend claims to third parties by non-resident taxpayers

by Latham & Watkins LLP on

Federal Ministry of Finance: If the capital gain is not taxable in Germany, the correspondent dividends are taxed. With its circular letter dated 26 July 2013, the Federal Ministry of Finance comments on the tax...more

IRS Releases Final and New Proposed Regulations That Define “Dividend Equivalent” for U.S. Withholding Tax Purposes

by Morrison & Foerster LLP on

On December 5, 2013, the Internal Revenue Service (“IRS”) finalized temporary regulations and issued new proposed regulations under Section 871(m), the Internal Revenue Code provision that treats “dividend equivalents” paid...more

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