Gregg D LemeinStewart R LipelesJohn D McDonald and Jefferson VanderWolk Partners Baker & McKenzie write on the new US legislation on tax-advantaged repatriation of foreign earnings
In last week's article (The Tax Journal 28 February 2005 Issue 778) we discussed the requirements of new s 965 of the US Internal Revenue Code which provides for a dividends-received deduction (DRD) in respect of a cash dividend from a controlled foreign corporation (CFC) to a US corporate shareholder. Essentially the taxpayer can deduct 85% of cash dividends from CFCs during a one-year period elected by the taxpayer subject to certain conditions the most notable of which is that the taxpayer must have adopted a plan to reinvest the cash in...
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Gregg D LemeinStewart R LipelesJohn D McDonald and Jefferson VanderWolk Partners Baker & McKenzie write on the new US legislation on tax-advantaged repatriation of foreign earnings
In last week's article (The Tax Journal 28 February 2005 Issue 778) we discussed the requirements of new s 965 of the US Internal Revenue Code which provides for a dividends-received deduction (DRD) in respect of a cash dividend from a controlled foreign corporation (CFC) to a US corporate shareholder. Essentially the taxpayer can deduct 85% of cash dividends from CFCs during a one-year period elected by the taxpayer subject to certain conditions the most notable of which is that the taxpayer must have adopted a plan to reinvest the cash in...
If you are not a subscriber, subscribe now to read this content.
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