News & Analysis as of

Beneficial Owner Tax Liability Income Taxes

McDermott Will & Schulte

Economic Ownership of Shares Transferred as Collateral

Dividends from shares are taxable for shareholders, even if the dividends do not remain with them economically. This (not entirely new) finding can be gleaned from a recent Federal Fiscal Court (BFH) ruling in which the...more

Freeman Law

FDAP Income

Freeman Law on

The United States generally taxes nonresident aliens and foreign corporations on their U.S.-source income. A foreign taxpayer’s U.S.-source income falls into one of two general categories: (i) “fixed or determinable annual...more

White & Case LLP

German IP Withholding Tax

White & Case LLP on

On November 6, 2020, the German Federal Ministry of Finance issued a decree addressing certain open questions relating to foreign taxpayers’ obligation to submit tax filings for royalty income derived from intellectual...more

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