The Resource Controlled foreign corporations' distributions were not qualified dividend income

Controlled foreign corporations' distributions were not qualified dividend income

Label
Controlled foreign corporations' distributions were not qualified dividend income
Title
Controlled foreign corporations' distributions were not qualified dividend income
Subject
Language
eng
Summary
The Tax Court, in Smith, 151 TC No. 5 (2018), determined that dividends paid to taxpayers from their controlled foreign corporations (CFCs) were not "qualified dividend income" (QDI) and thus did not qualify for Section 1(h)'s reduced tax rate. The court also held that a CFC's cancellation of an account receivable owed to it by the taxpayers' S corporation resulted in a constructive distribution to them
Citation source
In: Practical tax strategies. - Hoboken. - Vol. 102 (2019), no. 1 ; p. 36-38
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • CFC
  • dividend
  • constructive dividend
  • entity classification
  • income classification
  • reorganization
  • case law
Label
Controlled foreign corporations' distributions were not qualified dividend income
Instantiates
Publication
Label
Controlled foreign corporations' distributions were not qualified dividend income
Publication

Library Locations

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      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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