Topic
Dividends
88 published works
Global Regulation Tomorrow
ECB recommendation to delay dividends until October 2020
By Jochen Vester (UK), Simon Lovegrove (UK)
On 27 March 2020, the European Central Bank (ECB) updated its recommendation to banks on dividend distributions. The ECB recommends that at least until 1 October 2020 no dividends are…
Global Regulation Tomorrow
ECB recommendation on dividend distribution policies
By Simon Lovegrove (UK), Jochen Vester (UK)
On 21 January 2020, the European Central Bank (ECB) published a letter from Andrea Enria, ECB Supervisory Board Chair, to significant institutions supervised under the Single Supervisory Mechanism (SSM) regarding…
DLA Piper Latin America – Law Blog
Argentina imposes foreign exchange controls and obligations to repatriate exports proceeds
By DLA Piper
By: Martin Mittelman and Augusto Mancinelli On September 1, 2019, the Argentine Government issued Executive Decree No. 609/2019 (the “Decree”) which reinstated certain foreign exchange restrictions that had been in…
SALT Shaker
Montana Supreme Court Holds Actual Dividends Fully Deductible in Water’s-Edge Case
The Montana Supreme Court held that the Department erred in determining that Exxon Mobil was entitled to only an 80% exclusion for dividends received from domestic corporations excluded from the…
Down the Wire
Towards a “Distribution Policy”
The Investment Association ("IA") has published an interesting report following its investigation into dividend payment practices of UK listed companies. The research was carried out in response to the Department…
Tax Talks
Final IRS Regulations Sync Section 956 with TCJA Participation Exemption – Limits “Deemed Dividends” for U.S. Corporate Shareholders of CFCs
By Richard M. Corn, Muhyung (Aaron) Lee, Amanda H. Nussbaum, David S. Miller, Jeremy Naylor, Martin T. Hamilton, Malcolm Hochenberg
Implements 2018 Proposed Regulations, ending most limitations on investments in U.S. property, as well as pledges and guarantees by CFCs wholly-owned by U.S. corporations – also provides PTI guidance for CFC…
European Union and Italian International Tax Law Blog
Italy’s Regional Tax Court Denies Dividend Withholding Tax Exemption In the Absence Of Actual Taxation In the Country of Residence
By Marco Rossi
By way of ruling n. 55/6/2019 filed on January 21, 2019, the Regional Tax Court of Abruzzo held that no withholding tax exemption under the EU Parent-Subsidiary Directive applies, unless…
Restructuring Globalview
Careful Consideration Can Pay Dividends
Following our 2016 article, the Court of Appeal has upheld the decision of the High Court that dividends are liable to challenge as transactions defrauding creditors under section 423 of…
Free Writings + Perspectives
Social Costs of Dividends and Repurchases
In a recent paper, referenced above, author JB Heaton analyzes the extent to which the ability of corporations to return capital to their shareholders through dividends and repurchases results in…
Botinha & Cabral - International Business
Repatriation of Capitals after: Doing Business in Brazil
By Bootie
Repatriation of Capitals after Doing business in Brazil Dividends Dividends are withholding income tax free regardless if paid to a tax treaty country or tax haven jurisdiction or not.…