Corporate Taxes, Internal Revenue Code (IRC), Dividends

Nebraska Clarifies Treatment of IRC 965 Repatriation Income

Pillsbury - SeeSalt Blog on 9/20/2019

Nebraska’s tax department has issued guidance confirming its position that IRC 965 deemed repatriation income: 1) must be included in a taxpayer’s corporate income tax base (less the IRC 965(c) deduction); and 2) does not...more

Fine-tuning the course - Final Regulations enhance symmetry between taxation of actual dividends and section 956 inclusions

Eversheds Sutherland (US) LLP on 5/31/2019

On May 23, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (TD 9859) (the Final Regulations) modifying the application of section 956 of the Internal Revenue...more

IRS Paves the Way for Lenders to Obtain Guarantees and Collateral From (and 100% Stock Pledges of) Foreign Subsidiaries

Kramer Levin Naftalis & Frankel LLP on 11/16/2018

Background On Oct. 31, 2018, the Internal Revenue Service issued proposed regulations under Section 956 of the Internal Revenue Code that will eliminate the adverse tax consequences when a U.S. parent corporation (i)...more

The Death of the Deemed Dividend

Burns & Levinson LLP on 11/14/2018

The “deemed dividend” rule, the source of much wrangling between multi-national borrowers and lenders over the years, may be on its way out....more

Deemed participation better than no participation? Proposed regulations expand tax-free treatment to section 956 inclusions of...

Eversheds Sutherland (US) LLP on 11/7/2018

On October 31, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) modifying the application of section 956 of the Internal Revenue Code of...more

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 1 - A General Overview on Issues That U.S. and Mexican...

Holland & Knight LLP on 7/23/2018

• The Tax Cuts and Jobs Act (Tax Act), signed into law on Dec. 22, 2017, made significant changes to the manner in which U.S. corporate and individual taxpayers are taxed on income from international operations. • The Tax...more

Changes Abound in New Tax Bill for Multinational Companies

Williams Mullen on 1/9/2018

Perhaps some of the most extensive changes in H.R. 1, known as the Tax Cuts and Jobs Act (the “Act”), deal with the taxation of multinational companies. The taxation of foreign earnings has long been a point of contention...more

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

Foley & Lardner LLP on 3/15/2017

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

Corporate Taxes › Internal Revenue Code (IRC) › Dividends

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