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...
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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...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")