Topic
Dividends
86 published works
Dentons Insights
German’s Highest Tax Court Opens the Door to 0% Withholding on Dividends for U.S. S Corporation Shareholders
By Dentons
When a German company pays a dividend to a U.S. taxpayer, Germany generally withholds tax on those payments at a rate of 26.375%.
Thomson Reuters Law Blog
When a dividend basket turns into a debt basket
By Jamesju
Jump to ↓ The trick in the covenant A term to watch Highlights Available Restricted Payment Capacity baskets let borrowers repurpose dividend capacity into new, often pari-ranking debt. Noetica…
Blog of Digital Law and New Technologies
Difference between dividends and interim dividends
By LetsLaw
When a company generates profits, it may remunerate its shareholders by distributing dividends. An ordinary dividend is the classic distribution approved after the financial year has been closed and the…
European Union and Italian International Tax Law Blog
Taxation of Outbound Dividends and Free Movement of Capital: Developments in Italian and European Case Law
By Marco Rossi
Introduction The taxation of outbound dividends has been the subject of intense litigation in Italy and across Europe, particularly where non-E.U. entities are treated less favorably than similarly situated EU-based…
Fiscalidad Foral
Es contraria al derecho de la UE la normativa española sobre retenciones por dividendos pagados a accionistas extranjeros
By Garrigues
Según el Tribunal de Justicia de la Unión Europea, la normativa vizcaína del Impuesto sobre la Renta de No Residentes otorga un tratamiento distinto a las retenciones soportadas por accionistas…
It's Just Business
Court Declines to Undo a Corporate Board’s Vote that a Disgruntled Shareholder Skipped
In a costly episode of Aaron Sorkin’s adage that “decisions are made by those who show up,” the majority shareholder in a pair of family-controlled oil and gas companies learned…
Restructuring Globalview
Decision of the German Court Causes Waves For Investors but is Welcomed by Creditors of Insolvent Companies
In September 2023, the insolvency administrator of the insolvent Wirecard AG began reclaiming dividend distributions for 2017 and 2018 from shareholders. This is following a judgment of the Federal Court…
European Union and Italian International Tax Law Blog
Some further thoughts on the Italian Supreme Court’s dividend foreign tax credit ruling: very good news for taxpayers, or a potential misunderstanding?
By Marco Rossi
On September 1, 2022, the Italian Supreme Court issued a ruling (n. 25698) in a case concerning a distribution from a U.S. partnership treated as a taxable dividend in Italy.…
The CLS Blue Sky Blog
The Unsung Upside of Share Repurchases
Stock repurchases by issuing corporations have always been controversial. But they have become even more so recently because of the perception that the excess funds used to finance buybacks have…
Tax Talks
New Guidance Allows Publicly-Offered REITs and RICs to Issue up to 90% of Qualifying Dividends in the REIT or RIC’s Own Stock Through June 2022
By Martine Seiden Agatston, Martin T. Hamilton, Talia Jaffe, David S. Miller
On November 30, 2021, the IRS issued Revenue Procedure 2021-53, which temporarily allows publicly offered RICs and REITs to make distributions that are treated as dividends of up to 90%…