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Tax Treaty Stocks

Tax Treaty Savings Clause Question

by Charles (Chuck) Rubin on

Facts: A U.S. citizen and permanent resident of Israel incurs capital gains from the sale of stock of a U.S. corporation. U.S. - Israel Income Tax Treaty Provisions: Article 15, Paragraph 1: “[a] resident of one of...more

Planning For Qualified Dividend Income When Taking Foreign Companies Public - Tax Update Volume 2015, Issue 2

by Pepper Hamilton LLP on

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

2013 Amendments to United States and Japan Income Tax Treaty

by Baker Donelson on

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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