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Taxation Dividends

Cadwalader, Wickersham & Taft LLP

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

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

Morgan Lewis

Taxation of Dividends Received by Non-Residents in Kazakhstan Starting 2026

Morgan Lewis on

Kazakhstan will soon adopt a new tax code, with the bill currently in Parliament. It is expected that the new tax code will be adopted this year and come into force beginning 2026. This LawFlash summarizes the general...more

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

Dorsey & Whitney LLP

Certain Canadian Corporations May Unknowingly be Subject to U.S. Federal Backup Withholding and Reporting Requirements With...

Dorsey & Whitney LLP on

Canadian corporations making dividend payments should ensure that they are compliant with U.S. federal backup withholding and reporting requirements to avoid potential U.S. federal income tax issues....more

Hogan Lovells

New IRS proposed regulations under Section 956 substantially reduce "deemed dividend" concerns with respect to pledges and...

Hogan Lovells on

Until the issuance of the Proposed Regulations described below, under Section 956 of the Internal Revenue Code of 1986 (IRC) and Treasury Regulations thereunder, deemed dividends were potentially created when a U.S. borrower...more

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