Topic
Dividends
88 published works
Securities Law Prof Blog
Deutsche Boerse & NYSE Euronext Plan a Special Dividend after Closing
Deutsche Boerse AG and NYSE Euronext announced that they have recommended to the Board of Directors of the holding company of the merged group, Alpha Beta Netherlands Holding N.V. (“Holdco”), to pay…
SALT Shaker
California Double Whammy: Dividends Are Apportionable Income, Not Deductible
The California Board of Equalization (BOE) recently issued a decision holding that dividends received by an out-of-state corporate taxpayer were business income because the dividend payor played an integral and…
Tax, Trusts & Estates Law
Corporate Distributions Before 2011 Are a Worthwhile Consideration
The maximum 15% income tax rate on qualified dividends now in effect is scheduled to expire at the end of 2010. If Congress does not act, then beginning in 2011…
M & A Law Prof Blog
Cash on the Balance Sheet
By CorporateAcquisitions MergerLawBlogger
This morning's WSJ has anarticle suggesting that goods times are just around the corner forM&A lawyers. Actually, it's an article about the hole that ispresently being burned in the pockets of managers…
European Union and Italian International Tax Law Blog
Circular 26/E of May 21, 2009 Provides Guidance on EU Dividends Withholding Tax
By Marco Rossi
Italy issued circular n. 26/E of May 21, 2009 which provides clarifications on the new EU dividend withholding tax. The reduced tax rate of 1.375 percent applies to dividends paid…
European Union and Italian International Tax Law Blog
Italian Supreme Court Rules on Application of Tax Treaty Benefits to Partnerships
By Marco Rossi
Italian Supreme Court denied treaty benefits to dividends paid to a US limited partnership. US LP did not qualify for treaty benefits under the US-Italy treaty since fiscally transparent in…
European Union and Italian International Tax Law Blog
EU Parent-Subsidiary Directive Does Not Apply to Dividends on Shares Held in Usufruct, ECJ Ruled
By Marco Rossi
The European Curt of Justice ruled that the parent subsidiary directive, which exempts from withholding tax dividends paid from a EU subsidiary to a EU parent, does not apply to…
European Union and Italian International Tax Law Blog
Italian Supreme Court Applies General Anti-Avoidance Principle
By Marco Rossi
With two very important decisions issued on December 23, 2008 and concerning a dividend washing and dividend stripping transaction, the Italian Supreme Court for the first time applied a general…
European Union and Italian International Tax Law Blog
Withholding Tax on Outbound Dividends to a Luxemburg Investment SICAV Illegal, AG of the ECJ Says
By Marco Rossi
AG of ECJ issued his opinion in Aberdeen Property Fininvest Alpha, according to which no withholding tax should apply to dividends to a EU company (in the case, a Luxembourg…
Securities Law Prof Blog
Comcast Announces Plans to Return Cash to Shareholders
Comcast made two announcements designed to placate investors unhappy with its drop in stock price. It announced a 25 cents per year dividend -- its first since 1999 -- and…