Corporate Taxes, Dividends, Tax Court

La différence de traitement des quotes-parts de frais et charges selon la localisation des filiales conforme à la CEDH

Mayer Brown on 3/20/2025

La Cour administrative d'appel de Paris se prononce sur la conformité à la CEDH de la différence de traitement des quotes-parts de frais et charges selon la localisation des filiales (CAA Paris, 11 février 2025, n°...more

New Jersey Tax Court Rules Undistributed Foreign Earnings of CFC Are Not Taxable Dividends

Husch Blackwell LLP on 1/29/2025

A recent decision by the New Jersey Tax Court held that while taxpayers were required to report undistributed income from “deemed repatriation dividends” on their federal tax returns, they were not required to report that...more

Constructive Dividends and The Closely Held C Corporation

Rivkin Radler LLP on 3/21/2022

Withdrawing Value- Any tax adviser who has represented closely held businesses and their owners long enough realizes there are certain recurring themes that transcend the otherwise unique characteristics of the industry of...more

Corporate Tax Hike On The Horizon: Using Reasonable Compensation To Withdraw Value

Farrell Fritz, P.C. on 3/9/2021

Corporate Rate Increase? We begin this week with the Senate having passed the President’s $1.9 trillion coronavirus relief and economic stimulus plan (the “American Rescue Plan” following a marathon session during which...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

Renewed Perils from “Zeroing Out” a Corporation at Year-End

Dickinson Wright on 11/4/2016

Physicians who are involved in the financial management of their practices are all too familiar with the year-end scramble to “zero out” the corporation’s profits. Under this technique, a physician practice that is structured...more