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Income Taxes › Dividends

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Cadwalader, Wickersham & Taft LLP

Beard v HMRC: Capital Dividends. A Triumph of Form Over Substance?

Cadwalader, Wickersham & Taft LLP on

Introduction The recent UK Court of Appeal decision in Beard considered the treatment of dividends from a non-UK company, particularly the interpretation of ‘dividends of a capital nature’. In her leading judgment, Falk LJ...more

McDermott Will & Schulte

Economic Ownership of Shares Transferred as Collateral

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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

Mayer Brown

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

Mayer Brown on

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

International Lawyers Network

Establishing a Business Entity in Germany (Updated)

International Lawyers Network on

Anyone can establish a business in Germany - irrespective of citizenship, nationality, or place of residence. There is no specific investment legislation for foreign entrepreneurs. Any entrepreneur can make his choice...more

Morgan Lewis

PLF 2025 Adopted in France

Morgan Lewis on

The PLF 2025, definitively adopted by the Senate on 6 February 2025 following a months-long process, is currently being examined by the French Constitutional Council....more

Husch Blackwell LLP

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

Husch Blackwell LLP on

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

Blank Rome LLP

New Jersey Tax Court Rules That Individuals Are Not Subject to Tax on “Deemed Dividends” under IRC Section 965

Blank Rome LLP on

The New Jersey Tax Court has held that individual taxpayers were not required to include in their New Jersey gross income the undistributed earnings of controlled foreign corporations (“CFCs”) for purposes of the Gross Income...more

International Lawyers Network

Establishing a Business Entity in Brazil (Updated)

International Lawyers Network on

The two most common forms of legal entities incorporated in Brazil are the limited liability company (“Limitada”) and the corporation (“S.A.”). These are considered the most attractive types of companies given that they are...more

Cadwalader, Wickersham & Taft LLP

Extracting Value

Cadwalader, Wickersham & Taft LLP on

Establishing the timing of a corporate dividend can be an important feature in a number of transactions where value is being extracted from a company.  In the recent case of HMRC v Gould [2024] UKUT 00285 (TCC) (“Gould”), the...more

Baker Botts L.L.P.

Form SD Deadline Approaching for Resource Extraction Issuers: Reminder and FAQs

Baker Botts L.L.P. on

As previously discussed in our Client Alert issued on December 18, 2020 (available here), the U.S. Securities and Exchange Commission (the “Commission”) adopted its final rule (the “Final Rule,” available here) requiring...more

McDermott Will & Schulte

California Legislatively Overturns Recent Office of Tax Appeals Taxpayer Win

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The California State Legislature overturned Microsoft’s recent win at the Office of Tax Appeals, which held that the gross amount of dividends received from foreign affiliates outside its water’s-edge group should be included...more

Pillsbury - SeeSalt Blog

Reminder: “Gross” Does Not Mean “Net” – California OTA Holds All Repatriated Dividends Must Be Included in Sales Factor

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In a decision marked “not precedential,” the OTA held 100 percent of repatriated dividends must be included in the taxpayer’s sales factor denominator....more

McDermott Will & Schulte

Microsoft Scores Massive Win in California, Opens the Door for Others Nationwide

McDermott Will & Schulte on

The Office of Tax Appeals (OTA) handed Microsoft an enormous win in its controversy with the California Franchise Tax Board (FTB) over the inclusion of qualifying dividends in the sales factor denominator for which it also...more

International Lawyers Network

Establishing a Business Entity in Germany (Updated)

International Lawyers Network on

Anyone can establish a business in Germany - irrespective of citizenship, nationality, or place of residence. There is no specific investment legislation for foreign entrepreneurs. Any entrepreneur can make his choice from...more

Bilzin Sumberg

US-Chile Income Tax Treaty Enters Into Force

Bilzin Sumberg on

On December 19, 2023, the U.S. Treasury Department announced that the Income Tax Treaty between the United States and Chile (the “Treaty”) entered into force. The Treaty was originally signed in February of 2010, and, after...more

International Lawyers Network

Establishing a Business Entity in Brazil (Updated)

International Lawyers Network on

The two most common forms of legal entities incorporated in Brazil are the limited liability company (“Limitada”) and the corporation (“S.A.”). These are considered the most attractive types of companies given that they ...more

Rivkin Radler LLP

Activities Contrary to Public Policy – Revoking the Tax Exempt Status of Universities

Rivkin Radler LLP on

It appears that many of the country’s colleges and universities believe they have not already contributed enough to the decline of American education and to the erosion of our society, generally. These institutions of...more

Barnea Jaffa Lande & Co.

Ruling: Pre-Sale Dividend Distribution to Reduce Tax Liability

Barnea Jaffa Lande & Co. on

A district court ruling handed down this past September addresses the legitimacy of distributing dividends prior to a sale of shares in order to reduce the tax liability deriving from the transaction. The court found that, in...more

International Lawyers Network

Establishing A Business Entity In Lithuania (Updated)

International Lawyers Network on

1. Types of Business Entities - Investors may choose from the following types of business entities: • Private limited liability company • Public limited liability company • Individual enterprise • Limited...more

International Lawyers Network

Establishing a Business Entity in Germany (Updated)

International Lawyers Network on

Anyone can establish a business in Germany - irrespective of citizenship, nationality, or place of residence. There is no specific investment legislation for foreign entrepreneurs. Any entrepreneur can make his choice from...more

International Lawyers Network

Establishing A Business Entity In Brazil (Updated)

International Lawyers Network on

The two most common forms of legal entities incorporated in Brazil are the limited liability company (“Limitada”) and the corporation (“S.A.”). These are considered the most attractive types of companies given that they are...more

Holland & Knight LLP

En Colombia Consejo de Estado precisa tratamiento tributario de dividendos para régimen SIMPLE

Holland & Knight LLP on

Proferida dentro del expediente #26084 en sentencia de 10 de noviembre de 2022, al analizar la legalidad del artículo 3 del Decreto 1457 del 12 de noviembre de 2020, que regula el tratamiento de los dividendos y...more

Proskauer Rose LLP

UK Tax Round Up - November 2022

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Welcome to the November edition of the UK Tax Round Up. This month has seen the new Chancellor deliver his Autumn Statement following from the previous Chancellor’s so-called mini budget in October and the Court of Appeal’s...more

Orrick, Herrington & Sutcliffe LLP

UK Autumn Statement 2022 – key tax highlights

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On 17 November 2022, the UK Government announced a number of significant tax measures in its Autumn Statement. There were no real surprises this time as many of the measures had been trailed in recent days. The tax changes...more

Proskauer - Tax Talks

Massive U-Turn on Mini Budget

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As has been widely reported, a number of the Mini Budget proposals (summarised in our recent Tax Blog) have been scrapped. The new Chancellor of the Exchequer Jeremy Hunt announced these measures claiming that they are...more

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