Shareholders, Dividends, Tax Liability

Economic Ownership of Shares Transferred as Collateral

McDermott Will & Schulte on 5/6/2025

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

Extracting Value

Cadwalader, Wickersham & Taft LLP on 10/23/2024

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

Reasonable Compensation Meets The Principal Shareholder of a C Corp

Rivkin Radler LLP on 3/11/2022

Double Tax- The shareholders of C corporations have long sought legitimate operational and transactional structures by which they may reduce the double tax hit that is realized when such a corporation distributes its...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

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

The New Participation Exemption: An Opportunity to Convert Ordinary Dividends into Qualified Dividends

McDermott Will & Schulte on 6/19/2018

The Tax Cuts and Jobs Act introduced an important new benefit to US corporations that own 10 percent or more of a foreign corporation. Specifically, a full participation exemption has been enacted that exempts certain foreign...more

European M+A News, Winter 2016

Morrison & Foerster LLP on 2/11/2016

Smart Acquisition Structures For Deals In Germany And The UK - What Are the Criteria for Smart Acquisitions via Corporations? - Inbound investment structures seeking to acquire a German or UK corporation should take...more

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