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
Where Qualified Dividend Treatment Is Important, Serious Consideration Should Be Given to Ensuring the Company Is Eligible for Treaty Benefits Before Taking It Public.
Dividends generally are taxed at ordinary income...more
In a recent internal legal memorandum (the ILM), the IRS concluded that a US individual was entitled to treat dividends received from a Cypriot holding company with no Cypriot ownership as qualified dividend income (QDI), and...more
On January 24, 2013, the United States and Japan signed a proposed protocol to amend the existing tax treaty between the two countries, which was entered into in 2003. The amendments, which will take effect when ratified by...more
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