Foreign qualified dividends
•
2 likes•2,914 views
Foreign Qualified Dividends Eligibility Requirements and qualified foreign corporations; interaction with PFIC - Passive Foreign Investment Companies
Report
Share
Report
Share
Recommended
Contract financing
This document discusses contract financing for non-commercial purchases. It defines contract financing as authorized government payments to contractors prior to acceptance of supplies or services. It outlines different types of contract financing including progress payments based on cost, performance-based payments, and advance payments. It also discusses establishing financing terms, mitigating repayment and non-performance risks, and incorporating appropriate clauses into contracts for different financing methods. The overall purpose is to explain considerations and options for providing financing on non-commercial government contracts.
NAFTA Chapter 11: The Investor's Weapon of Choice
This slide deck covers NAFTA and Chapter 11, the Chapter 11 Claim Procedure, and substantive investor protections under Chapter 11. It explains the highly important Most-Favored Nation (MFN), Minimum Standard of Treatment, Performance Requirements and Expropriation provisions.
Foreign Persons Owning U.S. Real Estate
This document summarizes key tax rules regarding foreign investment in U.S. real estate, including FIRPTA rules. FIRPTA imposes a 10% tax on the sale of U.S. real property interests by foreign persons. It applies to direct and some indirect owners. There are procedures for withholding, exemptions, and taxpayer identification numbers. State tax rules also apply. Exceptions exist for principal residences, de minimis sales, and tax treaty benefits.
FIRPTA Presentation - 2015
This document summarizes topics related to FIRPTA (Foreign Investment in Real Property Tax Act):
1) It discusses FIRPTA rules regarding withholding agents, Form W-8ECI for claiming income is effectively connected to a U.S. trade or business, and Form W-7 for obtaining an ITIN.
2) It describes Form 8288-B for applying for a withholding certificate to reduce or eliminate withholding on dispositions of U.S. real property by foreign persons if they claim tax exemption or their maximum tax is less than required withholding.
3) The document notes it will cover entity and corporate structures and estate tax considerations but provides no details on those topics.
FATCA Essentials
Learn more about the Foreign Account Tax Compliance Act (FATCA), including FFI, NFFE, GIIN, FATCA Timeline, and more, from the International Tax Partners at Citrin Cooperman.
View the recorded FATCA webinar presentation here: http://www.citrincooperman.com/Webinars/FACTA-Webinar.aspx
www.citrincooperman.com
The Three Pillars of FATCA
The document discusses the Foreign Account Tax Compliance Act (FATCA) and its three pillars: classification, reporting, and withholding. It provides details on how financial institutions are required to classify accounts as U.S. or foreign, individuals as U.S. persons or not, and entities as foreign financial institutions, non-financial foreign entities, or excepted entities. It also outlines reporting obligations such as reporting on U.S. accounts annually to the IRS. [END SUMMARY]
Why And Where To Set Up A Foreign Trust For Asset Protection
A foreign trust must satisfy certain reporting requirements to the IRS, including filing Form 3520-A annually. The key forms are Form 3520-A, Form 5471 if owning a foreign corporation over 10%, and Form 8938 for foreign financial assets over a threshold. Whether a trust is domestic or foreign determines special reporting, and penalties can be imposed for failing to meet reporting rules. Understanding how and when to report a foreign trust to the IRS is important to avoid issues.
South africa merger review
The document summarizes South Africa's merger review process. It outlines that the Competition Act and Companies Act govern mergers, and foreign companies require Reserve Bank approval. It describes the types of combinations that fall under review, and that the Competition Commission and Tribunal oversee the process. Mergers must be formally notified if they meet threshold turnover/asset values. The review process examines likely competitive effects and potential offsets. Mergers can be approved with remedies, and there is no time limit for enforcing remedies.
Recommended
Contract financing
This document discusses contract financing for non-commercial purchases. It defines contract financing as authorized government payments to contractors prior to acceptance of supplies or services. It outlines different types of contract financing including progress payments based on cost, performance-based payments, and advance payments. It also discusses establishing financing terms, mitigating repayment and non-performance risks, and incorporating appropriate clauses into contracts for different financing methods. The overall purpose is to explain considerations and options for providing financing on non-commercial government contracts.
NAFTA Chapter 11: The Investor's Weapon of Choice
This slide deck covers NAFTA and Chapter 11, the Chapter 11 Claim Procedure, and substantive investor protections under Chapter 11. It explains the highly important Most-Favored Nation (MFN), Minimum Standard of Treatment, Performance Requirements and Expropriation provisions.
Foreign Persons Owning U.S. Real Estate
This document summarizes key tax rules regarding foreign investment in U.S. real estate, including FIRPTA rules. FIRPTA imposes a 10% tax on the sale of U.S. real property interests by foreign persons. It applies to direct and some indirect owners. There are procedures for withholding, exemptions, and taxpayer identification numbers. State tax rules also apply. Exceptions exist for principal residences, de minimis sales, and tax treaty benefits.
FIRPTA Presentation - 2015
This document summarizes topics related to FIRPTA (Foreign Investment in Real Property Tax Act):
1) It discusses FIRPTA rules regarding withholding agents, Form W-8ECI for claiming income is effectively connected to a U.S. trade or business, and Form W-7 for obtaining an ITIN.
2) It describes Form 8288-B for applying for a withholding certificate to reduce or eliminate withholding on dispositions of U.S. real property by foreign persons if they claim tax exemption or their maximum tax is less than required withholding.
3) The document notes it will cover entity and corporate structures and estate tax considerations but provides no details on those topics.
FATCA Essentials
Learn more about the Foreign Account Tax Compliance Act (FATCA), including FFI, NFFE, GIIN, FATCA Timeline, and more, from the International Tax Partners at Citrin Cooperman.
View the recorded FATCA webinar presentation here: http://www.citrincooperman.com/Webinars/FACTA-Webinar.aspx
www.citrincooperman.com
The Three Pillars of FATCA
The document discusses the Foreign Account Tax Compliance Act (FATCA) and its three pillars: classification, reporting, and withholding. It provides details on how financial institutions are required to classify accounts as U.S. or foreign, individuals as U.S. persons or not, and entities as foreign financial institutions, non-financial foreign entities, or excepted entities. It also outlines reporting obligations such as reporting on U.S. accounts annually to the IRS. [END SUMMARY]
Why And Where To Set Up A Foreign Trust For Asset Protection
A foreign trust must satisfy certain reporting requirements to the IRS, including filing Form 3520-A annually. The key forms are Form 3520-A, Form 5471 if owning a foreign corporation over 10%, and Form 8938 for foreign financial assets over a threshold. Whether a trust is domestic or foreign determines special reporting, and penalties can be imposed for failing to meet reporting rules. Understanding how and when to report a foreign trust to the IRS is important to avoid issues.
South africa merger review
The document summarizes South Africa's merger review process. It outlines that the Competition Act and Companies Act govern mergers, and foreign companies require Reserve Bank approval. It describes the types of combinations that fall under review, and that the Competition Commission and Tribunal oversee the process. Mergers must be formally notified if they meet threshold turnover/asset values. The review process examines likely competitive effects and potential offsets. Mergers can be approved with remedies, and there is no time limit for enforcing remedies.
Module 6 Taxation Of Foreign Taxpayers
This document provides an overview of the taxation of foreign taxpayers in the United States. It discusses two types of income subject to tax: income effectively connected to a U.S. business, which is taxed at progressive rates, and fixed or determinable annual or periodic income from U.S. sources, which is generally taxed at a 30% rate. Exceptions include portfolio interest, interest on securities, and gains from the sale of property that are not effectively connected. The Foreign Investment in Real Property Tax Act treats gains from the sale of U.S. real property as effectively connected income. The branch profits tax and earnings stripping rules aim to prevent base erosion through interest payments between related parties.
Doing business in the united states presentation 101028 (1)
The document provides an overview of key considerations for doing business in the United States, including:
1) Regulatory environment covers areas like antitrust, consumer protection, intellectual property, accounting standards.
2) Choice of entity includes LLC, LP, C Corp, S Corp which provide liability protection.
3) Transfer pricing is important for related party transactions to reflect arm's length prices and avoid penalties.
Capital mkt. & tax planning 23-6-2012(final)
details regarding stock market including bonus stripping and dividend stripping.
created by me for CA alok shah.
vadodara.
Fba rrevise2012 linkedinversion_
This document discusses the reporting requirements for foreign financial accounts and assets for individuals under the Bank Secrecy Act (FBAR) and the Foreign Account Tax Compliance Act (Form 8938). It explains that individuals must file an FBAR if they have a financial interest in or signature authority over foreign accounts totaling over $10,000 at any time during the year. Form 8938 must be filed if the aggregate value of foreign financial assets exceeds the reporting threshold. Failure to comply can result in civil and criminal penalties.
Foreign Account Tax Compliance Act (FATCA) - DSA Global Regulatory Conference
Presented by Jon Kutner, hyperWALLET General Counsel, at the 2014 DSA Global Regulatory Conference.
The Foreign Accounts Tax Compliance Act (FATCA) should be on the radar screen of every DSA member company. This presentation will begin with a background on the legislation and how it is being implemented globally, followed by a summary of how the FATCA rules interact with Section 1441/Non-resident alien withholding rules affecting DSOs paying distributors in foreign countries. The presentation will also cover FATCA issues affecting DSOs with business entities in foreign countries, and provide some suggestions for multinationals to prepare for FATCA due diligence requests from their foreign financial institutions.
Financial Markets & Services (FMS)- Types of Factoring- MBA
This document discusses types of factoring arrangements. It defines factoring as a relationship where a financial institution called a factor purchases a seller's receivables and controls/administers them. The main types discussed are:
- Recourse vs non-recourse factoring, depending on whether the seller assumes risk of unpaid invoices
- Domestic vs export factoring, depending on whether customer/factor/seller are in the same country
- Disclosed vs undisclosed factoring, depending on whether the factor is named on invoices
- Advance vs maturity vs invoice discounting vs bulk vs agency factoring, which differ in payment processes and responsibilities for administration/collection.
Bank Schedules Balance Sheet
The document outlines the various schedules that make up a bank's balance sheet and profit and loss statement. The balance sheet schedules include capital and liabilities such as reserves and surplus, deposits, borrowings, and other liabilities. Asset schedules include cash and bank balances, investments, advances, fixed deposits, and other assets. The profit and loss statement schedule outlines the components of interest earned, including interest/discount on loans less rebates, and interest accrued on investments.
FATCA Definitions, Terminology, and Criticisms
The document is a presentation on the Foreign Account Tax Compliance Act (FATCA) that defines key terms, outlines FATCA terminology, and discusses criticisms of FATCA. It contains definitions of terms like Foreign Financial Institution (FFI), Participating FFI, Deemed-Compliant FFI, Non-Financial Foreign Entity (NFFE), Internal Revenue Service (IRS), and Global Intermediary Identification Number (GIIN). It notes that FATCA terminology takes on specialized meanings and contexts. The presentation also lists 12 common criticisms of FATCA such as its complexity, unilateralism, extraterritoriality, disproportionate response, and negative impacts.
Financial Instruments - Introduction - CA Pooja Gupta
The document discusses financial instruments and their accounting treatment under Indian Accounting Standards. It defines financial instruments and covers their classification as financial assets, financial liabilities or equity. It discusses recognition, measurement, impairment and derecognition of financial instruments. The presentation also covers debt vs equity classification, compound financial instruments and accounting for derivatives like forward contracts.
Ias 39
IAS 39 establishes principles for recognizing and measuring financial assets, financial liabilities, and some contracts to buy or sell non-financial items. It aims to classify financial instruments into appropriate measurement categories and provides guidance on recognizing and derecognizing financial instruments, impairment of financial assets, and hedge accounting. IAS 39 has been replaced by IFRS 9 for annual periods beginning on or after January 1, 2013, though parts of IAS 39 remain in effect until fully replaced by future phases of IFRS 9.
S7C - The FATCA Regulatory Framework
The document provides an overview of the Foreign Account Tax Compliance Act (FATCA) regulatory framework. It defines key FATCA terms and concepts. It also outlines the main aims and objectives of FATCA, which are to combat offshore tax evasion by US persons and help pay for the US Hiring Incentives to Restore Employment Act. The document discusses FATCA's three pillars of classification, reporting, and withholding requirements. It also provides timelines of FATCA implementation.
Ifrs 9
Presentation with illustrations on Financial Instruments (IFRS 9) by accredited institute for CPA, CFA, IFRS, ACCA, CIMA
IAS 32: Presentation of Financial Instruments
The document provides an overview of IAS 32 Presentation of Financial Instruments. It discusses the objectives of IAS 32 which are to establish principles for presenting financial instruments and provide definitions to distinguish between equity and liabilities. It also covers definitions of key terms like financial instrument, financial asset, financial liability, and equity instruments. Additionally, it addresses requirements around compound financial instruments, treasury shares, and offsetting financial assets and liabilities. The document aims to clarify the rules and principles in IAS 32 around the classification and presentation of different types of financial instruments.
Iw8ben
This document provides instructions for Form W-8BEN, which is used by individuals to establish foreign status for U.S. tax purposes and claim tax treaty benefits. Key points include:
- Form W-8BEN is used by individuals to document foreign status and claim tax treaty benefits to avoid 30% withholding on U.S. source income like interest, dividends, and royalties.
- The form has been updated to reflect new FATCA requirements for foreign financial institutions to identify U.S. account holders and comply with new information reporting and withholding rules.
- Individuals must provide the form to withholding agents to avoid being subject to 30% withholding or being classified as a
International Business Tips from Attorney
The document discusses 10 key international business considerations for companies conducting business abroad, including: choosing governing law and regional restrictions; hiring local attorneys; complying with the Foreign Corrupt Practices Act; using international licensing as an alternative to subsidiaries; understanding duties and consumer protection laws; learning Incoterms definitions; ensuring proper documentation of sale; and using international arbitration for dispute resolution.
Irish Revenue Article On Islamic Finance 1009
The document provides an overview of the tax treatment of Islamic finance products and structures in funds, leasing, and insurance. It outlines that Shari'a compliant funds are taxed similarly to conventional funds under Irish tax law. Ijarah (leasing) arrangements are generally taxed the same as conventional leases depending on whether they are operating leases, finance leases, or hire purchases. Takaful (Islamic insurance) and ReTakaful (Islamic reinsurance) arrangements are taxed similarly to conventional insurance/reinsurance with contributions and expenses treated comparably.
Holdings Brauner lob presentation
The document discusses the United States' use of limitation on benefits (LOB) clauses in tax treaties to prevent treaty shopping. It provides background on the development of LOB provisions, describing early treaty shopping schemes and the US response. It outlines the key tests in LOB articles, including ownership/base erosion tests and active trade or business tests. It also discusses the interaction of LOB clauses with European Union law and whether they infringe on treaty freedoms.
Holdings Brauner lob presentation
The document discusses the United States' limitation on benefits (LOB) rules and European tax law. It provides background on the development of the US LOB policy, which aims to prevent treaty shopping. The US LOB rules include tests like the ownership/base erosion test and public company test. It examines several US court cases related to treaty benefits and outlines the key components and history of the LOB article in US tax treaties.
Welcome To America: Doing Business in the United States
Royse Law firm offers an introduction into the elements one should consider when establishing a business in the United States.
Hot topics for venture capital funds
The document discusses several hot topics for venture capital funds regarding US and foreign tax compliance and planning, including:
1) Recent US tax law changes affecting carried interest taxation and foreign bank account reporting.
2) Obama's proposals to tax carried interest as ordinary income and require self-employment taxes.
3) Considerations for structuring foreign subsidiaries and holdings to minimize tax liability, such as holding carried interest in an Israeli corporation.
4) Requirements and penalties for filing Form 5471 for foreign subsidiaries and Form TD F 90-22.1 for foreign bank accounts, and the implications for VC funds.
How capital gain is to be computed when superstructure (building) less than 3...
How capital gain is to be computed when superstructure (building) less than 3 years old and constructed on an old land owned for more than 3 years is sold - T. N. Pandey - Article published in Business Advisor, dated February 10, 2015 http://www.magzter.com/IN/Shrinikethan/Business-Advisor/Business/
Blue city holdings limited form f-1
This document provides an initial public offering prospectus for BlueCity Holdings Limited. It summarizes BlueCity's business, which began in 2000 as an online forum for China's LGBTQ community. BlueCity has since grown to offer a suite of mobile services for the LGBTQ community in China and Asia, including social networking, entertainment, health, and family planning services. As of March 2020, BlueCity's Blued mobile app had over 49 million registered users. The prospectus provides financial and operating data for BlueCity and details of the proposed IPO.
More Related Content
What's hot
Module 6 Taxation Of Foreign Taxpayers
This document provides an overview of the taxation of foreign taxpayers in the United States. It discusses two types of income subject to tax: income effectively connected to a U.S. business, which is taxed at progressive rates, and fixed or determinable annual or periodic income from U.S. sources, which is generally taxed at a 30% rate. Exceptions include portfolio interest, interest on securities, and gains from the sale of property that are not effectively connected. The Foreign Investment in Real Property Tax Act treats gains from the sale of U.S. real property as effectively connected income. The branch profits tax and earnings stripping rules aim to prevent base erosion through interest payments between related parties.
Doing business in the united states presentation 101028 (1)
The document provides an overview of key considerations for doing business in the United States, including:
1) Regulatory environment covers areas like antitrust, consumer protection, intellectual property, accounting standards.
2) Choice of entity includes LLC, LP, C Corp, S Corp which provide liability protection.
3) Transfer pricing is important for related party transactions to reflect arm's length prices and avoid penalties.
Capital mkt. & tax planning 23-6-2012(final)
details regarding stock market including bonus stripping and dividend stripping.
created by me for CA alok shah.
vadodara.
Fba rrevise2012 linkedinversion_
This document discusses the reporting requirements for foreign financial accounts and assets for individuals under the Bank Secrecy Act (FBAR) and the Foreign Account Tax Compliance Act (Form 8938). It explains that individuals must file an FBAR if they have a financial interest in or signature authority over foreign accounts totaling over $10,000 at any time during the year. Form 8938 must be filed if the aggregate value of foreign financial assets exceeds the reporting threshold. Failure to comply can result in civil and criminal penalties.
Foreign Account Tax Compliance Act (FATCA) - DSA Global Regulatory Conference
Presented by Jon Kutner, hyperWALLET General Counsel, at the 2014 DSA Global Regulatory Conference.
The Foreign Accounts Tax Compliance Act (FATCA) should be on the radar screen of every DSA member company. This presentation will begin with a background on the legislation and how it is being implemented globally, followed by a summary of how the FATCA rules interact with Section 1441/Non-resident alien withholding rules affecting DSOs paying distributors in foreign countries. The presentation will also cover FATCA issues affecting DSOs with business entities in foreign countries, and provide some suggestions for multinationals to prepare for FATCA due diligence requests from their foreign financial institutions.
Financial Markets & Services (FMS)- Types of Factoring- MBA
This document discusses types of factoring arrangements. It defines factoring as a relationship where a financial institution called a factor purchases a seller's receivables and controls/administers them. The main types discussed are:
- Recourse vs non-recourse factoring, depending on whether the seller assumes risk of unpaid invoices
- Domestic vs export factoring, depending on whether customer/factor/seller are in the same country
- Disclosed vs undisclosed factoring, depending on whether the factor is named on invoices
- Advance vs maturity vs invoice discounting vs bulk vs agency factoring, which differ in payment processes and responsibilities for administration/collection.
Bank Schedules Balance Sheet
The document outlines the various schedules that make up a bank's balance sheet and profit and loss statement. The balance sheet schedules include capital and liabilities such as reserves and surplus, deposits, borrowings, and other liabilities. Asset schedules include cash and bank balances, investments, advances, fixed deposits, and other assets. The profit and loss statement schedule outlines the components of interest earned, including interest/discount on loans less rebates, and interest accrued on investments.
FATCA Definitions, Terminology, and Criticisms
The document is a presentation on the Foreign Account Tax Compliance Act (FATCA) that defines key terms, outlines FATCA terminology, and discusses criticisms of FATCA. It contains definitions of terms like Foreign Financial Institution (FFI), Participating FFI, Deemed-Compliant FFI, Non-Financial Foreign Entity (NFFE), Internal Revenue Service (IRS), and Global Intermediary Identification Number (GIIN). It notes that FATCA terminology takes on specialized meanings and contexts. The presentation also lists 12 common criticisms of FATCA such as its complexity, unilateralism, extraterritoriality, disproportionate response, and negative impacts.
Financial Instruments - Introduction - CA Pooja Gupta
The document discusses financial instruments and their accounting treatment under Indian Accounting Standards. It defines financial instruments and covers their classification as financial assets, financial liabilities or equity. It discusses recognition, measurement, impairment and derecognition of financial instruments. The presentation also covers debt vs equity classification, compound financial instruments and accounting for derivatives like forward contracts.
Ias 39
IAS 39 establishes principles for recognizing and measuring financial assets, financial liabilities, and some contracts to buy or sell non-financial items. It aims to classify financial instruments into appropriate measurement categories and provides guidance on recognizing and derecognizing financial instruments, impairment of financial assets, and hedge accounting. IAS 39 has been replaced by IFRS 9 for annual periods beginning on or after January 1, 2013, though parts of IAS 39 remain in effect until fully replaced by future phases of IFRS 9.
S7C - The FATCA Regulatory Framework
The document provides an overview of the Foreign Account Tax Compliance Act (FATCA) regulatory framework. It defines key FATCA terms and concepts. It also outlines the main aims and objectives of FATCA, which are to combat offshore tax evasion by US persons and help pay for the US Hiring Incentives to Restore Employment Act. The document discusses FATCA's three pillars of classification, reporting, and withholding requirements. It also provides timelines of FATCA implementation.
Ifrs 9
Presentation with illustrations on Financial Instruments (IFRS 9) by accredited institute for CPA, CFA, IFRS, ACCA, CIMA
IAS 32: Presentation of Financial Instruments
The document provides an overview of IAS 32 Presentation of Financial Instruments. It discusses the objectives of IAS 32 which are to establish principles for presenting financial instruments and provide definitions to distinguish between equity and liabilities. It also covers definitions of key terms like financial instrument, financial asset, financial liability, and equity instruments. Additionally, it addresses requirements around compound financial instruments, treasury shares, and offsetting financial assets and liabilities. The document aims to clarify the rules and principles in IAS 32 around the classification and presentation of different types of financial instruments.
Iw8ben
This document provides instructions for Form W-8BEN, which is used by individuals to establish foreign status for U.S. tax purposes and claim tax treaty benefits. Key points include:
- Form W-8BEN is used by individuals to document foreign status and claim tax treaty benefits to avoid 30% withholding on U.S. source income like interest, dividends, and royalties.
- The form has been updated to reflect new FATCA requirements for foreign financial institutions to identify U.S. account holders and comply with new information reporting and withholding rules.
- Individuals must provide the form to withholding agents to avoid being subject to 30% withholding or being classified as a
International Business Tips from Attorney
The document discusses 10 key international business considerations for companies conducting business abroad, including: choosing governing law and regional restrictions; hiring local attorneys; complying with the Foreign Corrupt Practices Act; using international licensing as an alternative to subsidiaries; understanding duties and consumer protection laws; learning Incoterms definitions; ensuring proper documentation of sale; and using international arbitration for dispute resolution.
Irish Revenue Article On Islamic Finance 1009
The document provides an overview of the tax treatment of Islamic finance products and structures in funds, leasing, and insurance. It outlines that Shari'a compliant funds are taxed similarly to conventional funds under Irish tax law. Ijarah (leasing) arrangements are generally taxed the same as conventional leases depending on whether they are operating leases, finance leases, or hire purchases. Takaful (Islamic insurance) and ReTakaful (Islamic reinsurance) arrangements are taxed similarly to conventional insurance/reinsurance with contributions and expenses treated comparably.
What's hot (16)
Doing business in the united states presentation 101028 (1)
Doing business in the united states presentation 101028 (1)
Foreign Account Tax Compliance Act (FATCA) - DSA Global Regulatory Conference
Foreign Account Tax Compliance Act (FATCA) - DSA Global Regulatory Conference
Financial Markets & Services (FMS)- Types of Factoring- MBA
Financial Markets & Services (FMS)- Types of Factoring- MBA
Financial Instruments - Introduction - CA Pooja Gupta
Financial Instruments - Introduction - CA Pooja Gupta
Similar to Foreign qualified dividends
Holdings Brauner lob presentation
The document discusses the United States' use of limitation on benefits (LOB) clauses in tax treaties to prevent treaty shopping. It provides background on the development of LOB provisions, describing early treaty shopping schemes and the US response. It outlines the key tests in LOB articles, including ownership/base erosion tests and active trade or business tests. It also discusses the interaction of LOB clauses with European Union law and whether they infringe on treaty freedoms.
Holdings Brauner lob presentation
The document discusses the United States' limitation on benefits (LOB) rules and European tax law. It provides background on the development of the US LOB policy, which aims to prevent treaty shopping. The US LOB rules include tests like the ownership/base erosion test and public company test. It examines several US court cases related to treaty benefits and outlines the key components and history of the LOB article in US tax treaties.
Welcome To America: Doing Business in the United States
Royse Law firm offers an introduction into the elements one should consider when establishing a business in the United States.
Hot topics for venture capital funds
The document discusses several hot topics for venture capital funds regarding US and foreign tax compliance and planning, including:
1) Recent US tax law changes affecting carried interest taxation and foreign bank account reporting.
2) Obama's proposals to tax carried interest as ordinary income and require self-employment taxes.
3) Considerations for structuring foreign subsidiaries and holdings to minimize tax liability, such as holding carried interest in an Israeli corporation.
4) Requirements and penalties for filing Form 5471 for foreign subsidiaries and Form TD F 90-22.1 for foreign bank accounts, and the implications for VC funds.
How capital gain is to be computed when superstructure (building) less than 3...
How capital gain is to be computed when superstructure (building) less than 3 years old and constructed on an old land owned for more than 3 years is sold - T. N. Pandey - Article published in Business Advisor, dated February 10, 2015 http://www.magzter.com/IN/Shrinikethan/Business-Advisor/Business/
Blue city holdings limited form f-1
This document provides an initial public offering prospectus for BlueCity Holdings Limited. It summarizes BlueCity's business, which began in 2000 as an online forum for China's LGBTQ community. BlueCity has since grown to offer a suite of mobile services for the LGBTQ community in China and Asia, including social networking, entertainment, health, and family planning services. As of March 2020, BlueCity's Blued mobile app had over 49 million registered users. The prospectus provides financial and operating data for BlueCity and details of the proposed IPO.
Legal overview star camp royse - may 2020 4839-7571-5260-1
This document provides an overview of legal considerations for forming and financing a startup called StarCamp. It discusses the differences between establishing a US branch versus incorporating in the US. Key topics covered include effectively connected income, branch profits tax, withholding taxes and how tax treaties may provide relief, transfer pricing requirements, and BEA reporting filings. The document also examines choice of entity options, tax benefits of C corporations, founder equity splits, vesting, and employment law issues around worker classification.
Cole, john far-report
John Cole certified that he read and understands the FAR and DFARS provisions. He represents that the information provided is accurate and understands he could face criminal or civil penalties for misrepresenting information to the government. The document contains Cole's certification of independent price determination and disclosure regarding payments to influence federal transactions in accordance with FAR requirements.
Square, Inc SEC Form S-1 - IPO Filing
- Square provides sellers with credit card processing and other business services through a mobile app and card reader that attaches to mobile devices.
- Square started in 2009 with the goal of enabling anyone to accept card payments anywhere at any time. It has since expanded its offerings to include financial services and marketing services to help sellers start, run, and grow their businesses.
- Square has millions of sellers across various business types that processed $23.8 billion in payments in 2014. It aims to democratize commerce by providing accessible, intuitive, and affordable solutions for sellers of all sizes.
Module 5 Transfers Of Property
Section 367 and the dual consolidated loss rules prevent taxpayers from obtaining double tax benefits by using losses to offset income in both the United States and a foreign jurisdiction. The dual consolidated loss rules under Section 1503(d) define a dual consolidated loss as any net operating loss incurred by a domestic corporation that is also considered a resident for tax purposes in a foreign country. The rules are intended to prevent a dual resident company from using the same losses to obtain tax benefits in both the United States and another country.
rite aid company
Rite Aid's board of directors has proposed a reverse stock split to regain compliance with NYSE's share price listing rule after its stock price fell below $1 per share. All three leading proxy advisory firms, RiskMetrics, Glass Lewis, and Proxy Governance, have recommended that stockholders vote for the reverse stock split. The reverse stock split would proportionally increase the stock price and is necessary to avoid Rite Aid being delisted from the NYSE. Stockholders will vote on the reverse stock split at a special meeting on December 2nd.
slm ann10k__2003
This document is SLM Corporation's (Sallie Mae) annual report (Form 10-K) filed with the SEC for the fiscal year ending December 31, 2003. It provides an overview of Sallie Mae's business operations, including that it is a leading provider of education financing through federal and private student loans. It also defines various key terms related to student loans and financing. The report notes Sallie Mae is nearing completion of its privatization process from its original role as a government-sponsored enterprise, and now offers a range of credit and related services to support access to higher education.
257 clearchanne
Clear Channel Communications entered into an agreement to be acquired by private equity firms affiliated with Thomas H. Lee Partners and Bain Capital Partners. Under the terms of the agreement, shareholders will receive $37.60 per share in cash. The agreement includes provisions allowing Clear Channel to solicit other bids until certain dates and requires Clear Channel to pay termination fees to the buyers under certain circumstances. The employment agreements of key executives were also amended in connection with the transaction.
Chapter XVII: State owned enterprises and designated monopolies chapter
This document defines key terms related to state-owned enterprises and designated monopolies for the purposes of Chapter 17. It defines terms such as commercial activities, commercial considerations, designate, designated monopoly, government monopoly, monopoly, non-commercial assistance, public service mandate, sovereign wealth fund, and state-owned enterprise. It also outlines the scope of application of Chapter 17 to the activities of state-owned enterprises that affect trade or investment between parties within the free trade area, with exceptions for certain regulatory and monetary authorities.
slm ann10k_2002
This document is SLM Corporation's annual report (Form 10-K) filed with the SEC for the fiscal year ended December 31, 2002. It provides information on SLM's business operations, including that it is the largest holder and servicer of Federal Family Education Loan Program (FFELP) student loans, managing $79 billion in student loans. It discusses the student lending marketplace and trends driving growth, including rising tuition costs and the growing number of students relying on education loans. The report also outlines key terms and programs related to SLM's student lending business.
The Effect of Tax Reform on Real Estate and Professional Service Firms (Part 2)
The document discusses the impact of the Tax Cuts and Jobs Act (TCJA) on foreign partners in US partnerships. It explains that the TCJA enacted IRC Section 864(c)(8) to treat gains from the sale of partnership interests as effectively connected income (ECI) if the partnership conducts a US trade or business. The new law aims to tax foreign partners on disposition of partnership interests and requires transferee withholding of 10% of the amount realized on such dispositions.
BNA Daily Tax Report re NII Tax - JSH JGL PH - Dec 13
The document discusses whether foreign tax credits can be used to offset liability under the net investment income tax (NIIT) imposed by the US. It argues that while the IRS says tax treaties would not allow this based on standard language, the IRS interpretation is incorrect and inappropriate. The denial of relief from double taxation under the NIIT through tax treaties is wrong as a matter of treaty interpretation and tax policy, as treaties are meant to avoid double taxation on the same income across countries. The document maintains that tax treaties should permit offsetting the NIIT with foreign tax credits in certain cross-border situations where the NIIT otherwise results in double taxation for US citizens or residents living abroad.
Harmonized system glossary for oni 24
This document defines various tariff and trade-related terms used in international trade and customs. Some key terms defined include ad valorem duty, antidumping duty, countervailing duty, free trade agreements, rules of origin, Harmonized System, and Harmonized Tariff Schedule of the United States. The definitions provide clarity on concepts related to determining customs duties and establishing the origin of imported goods.
Foreign Remittance
The remittance of funds abroad from perspective of Income Tax Act, 1961 (“IT Act”) requires a clear understanding of its process flow (right from the applicability of the Act to the procedure in which the funds will be remitted outside India). By way of this presentation, we have tried to simplify the Income Tax provisions for remittance of funds abroad for our readers.
ICAI-Goa Branch - Presentation on Hybrid Financial Instruments - 16.12.2011
This document summarizes a presentation on hybrid financial instruments given by Mr. Paresh P. Shah. The presentation covered the meaning and types of hybrid instruments, their application for tax and commercial purposes, issues around their classification for tax purposes, and case studies of their taxation in the UK and US. Key points included that hybrid instruments have economic characteristics inconsistent with their legal form, creating flexibility but also tax issues. Classification depends on factors like investment risk and intent. The UK focuses on legal form while the US examines objective facts.
Similar to Foreign qualified dividends (20)
Welcome To America: Doing Business in the United States
Welcome To America: Doing Business in the United States
How capital gain is to be computed when superstructure (building) less than 3...
How capital gain is to be computed when superstructure (building) less than 3...
Legal overview star camp royse - may 2020 4839-7571-5260-1
Legal overview star camp royse - may 2020 4839-7571-5260-1
Chapter XVII: State owned enterprises and designated monopolies chapter
Chapter XVII: State owned enterprises and designated monopolies chapter
The Effect of Tax Reform on Real Estate and Professional Service Firms (Part 2)
The Effect of Tax Reform on Real Estate and Professional Service Firms (Part 2)
BNA Daily Tax Report re NII Tax - JSH JGL PH - Dec 13
BNA Daily Tax Report re NII Tax - JSH JGL PH - Dec 13
ICAI-Goa Branch - Presentation on Hybrid Financial Instruments - 16.12.2011
ICAI-Goa Branch - Presentation on Hybrid Financial Instruments - 16.12.2011
Recently uploaded
2022 Vintage Roman Numerals Men Rings
Discover timeless style with the 2022 Vintage Roman Numerals Men's Ring. Crafted from premium stainless steel, this 6mm wide ring embodies elegance and durability. Perfect as a gift, it seamlessly blends classic Roman numeral detailing with modern sophistication, making it an ideal accessory for any occasion.
https://rb.gy/usj1a2
Best practices for project execution and delivery
A select set of project management best practices to keep your project on-track, on-cost and aligned to scope. Many firms have don't have the necessary skills, diligence, methods and oversight of their projects; this leads to slippage, higher costs and longer timeframes. Often firms have a history of projects that simply failed to move the needle. These best practices will help your firm avoid these pitfalls but they require fortitude to apply.
Understanding User Needs and Satisfying Them
https://www.productmanagementtoday.com/frs/26903918/understanding-user-needs-and-satisfying-them
We know we want to create products which our customers find to be valuable. Whether we label it as customer-centric or product-led depends on how long we've been doing product management. There are three challenges we face when doing this. The obvious challenge is figuring out what our users need; the non-obvious challenges are in creating a shared understanding of those needs and in sensing if what we're doing is meeting those needs.
In this webinar, we won't focus on the research methods for discovering user-needs. We will focus on synthesis of the needs we discover, communication and alignment tools, and how we operationalize addressing those needs.
Industry expert Scott Sehlhorst will:
• Introduce a taxonomy for user goals with real world examples
• Present the Onion Diagram, a tool for contextualizing task-level goals
• Illustrate how customer journey maps capture activity-level and task-level goals
• Demonstrate the best approach to selection and prioritization of user-goals to address
• Highlight the crucial benchmarks, observable changes, in ensuring fulfillment of customer needs
Organizational Change Leadership Agile Tour Geneve 2024
Organizational Change Leadership at Agile Tour Geneve 2024
Mastering B2B Payments Webinar from BlueSnap
B2B payments are rapidly changing. Find out the 5 key questions you need to be asking yourself to be sure you are mastering B2B payments today. Learn more at www.BlueSnap.com.
How MJ Global Leads the Packaging Industry.pdf
MJ Global's success in staying ahead of the curve in the packaging industry is a testament to its dedication to innovation, sustainability, and customer-centricity. By embracing technological advancements, leading in eco-friendly solutions, collaborating with industry leaders, and adapting to evolving consumer preferences, MJ Global continues to set new standards in the packaging sector.
Zodiac Signs and Food Preferences_ What Your Sign Says About Your Taste
Know what your zodiac sign says about your taste in food! Explore how the 12 zodiac signs influence your culinary preferences with insights from MyPandit. Dive into astrology and flavors!
LA HUG - Video Testimonials with Chynna Morgan - June 2024
Have you ever heard that user-generated content or video testimonials can take your brand to the next level? We will explore how you can effectively use video testimonials to leverage and boost your sales, content strategy, and increase your CRM data.🤯
We will dig deeper into:
1. How to capture video testimonials that convert from your audience 🎥
2. How to leverage your testimonials to boost your sales 💲
3. How you can capture more CRM data to understand your audience better through video testimonials. 📊
Business storytelling: key ingredients to a story
Storytelling is an incredibly valuable tool to share data and information. To get the most impact from stories there are a number of key ingredients. These are based on science and human nature. Using these elements in a story you can deliver information impactfully, ensure action and drive change.
Authentically Social by Corey Perlman - EO Puerto Rico
Authentically Social by Corey Perlman - EO Puerto RicoCorey Perlman, Social Media Speaker and Consultant
Social media for business Dpboss Matka Guessing Satta Matta Matka Kalyan Chart Satta Matka
Dpboss Matka Guessing Satta Matta Matka Kalyan Chart Satta Matka➒➌➎➏➑➐➋➑➐➐Dpboss Matka Guessing Satta Matka Kalyan Chart Indian Matka
Dpboss Matka Guessing Satta Matta Matka Kalyan Chart Indian Matka Indian satta Matka Dpboss Matka Kalyan Chart Matka Boss otg matka Guessing Satta Part 2 Deep Dive: Navigating the 2024 Slowdown
Introduction
The global retail industry has weathered numerous storms, with the financial crisis of 2008 serving as a poignant reminder of the sector's resilience and adaptability. However, as we navigate the complex landscape of 2024, retailers face a unique set of challenges that demand innovative strategies and a fundamental shift in mindset. This white paper contrasts the impact of the 2008 recession on the retail sector with the current headwinds retailers are grappling with, while offering a comprehensive roadmap for success in this new paradigm.
Industrial Tech SW: Category Renewal and Creation
Every industrial revolution has created a new set of categories and a new set of players.
Multiple new technologies have emerged, but Samsara and C3.ai are only two companies which have gone public so far.
Manufacturing startups constitute the largest pipeline share of unicorns and IPO candidates in the SF Bay Area, and software startups dominate in Germany.
The Evolution and Impact of OTT Platforms: A Deep Dive into the Future of Ent...
This presentation provides a thorough examination of Over-the-Top (OTT) platforms, focusing on their development and substantial influence on the entertainment industry, with a particular emphasis on the Indian market.We begin with an introduction to OTT platforms, defining them as streaming services that deliver content directly over the internet, bypassing traditional broadcast channels. These platforms offer a variety of content, including movies, TV shows, and original productions, allowing users to access content on-demand across multiple devices.The historical context covers the early days of streaming, starting with Netflix's inception in 1997 as a DVD rental service and its transition to streaming in 2007. The presentation also highlights India's television journey, from the launch of Doordarshan in 1959 to the introduction of Direct-to-Home (DTH) satellite television in 2000, which expanded viewing choices and set the stage for the rise of OTT platforms like Big Flix, Ditto TV, Sony LIV, Hotstar, and Netflix. The business models of OTT platforms are explored in detail. Subscription Video on Demand (SVOD) models, exemplified by Netflix and Amazon Prime Video, offer unlimited content access for a monthly fee. Transactional Video on Demand (TVOD) models, like iTunes and Sky Box Office, allow users to pay for individual pieces of content. Advertising-Based Video on Demand (AVOD) models, such as YouTube and Facebook Watch, provide free content supported by advertisements. Hybrid models combine elements of SVOD and AVOD, offering flexibility to cater to diverse audience preferences.
Content acquisition strategies are also discussed, highlighting the dual approach of purchasing broadcasting rights for existing films and TV shows and investing in original content production. This section underscores the importance of a robust content library in attracting and retaining subscribers.The presentation addresses the challenges faced by OTT platforms, including the unpredictability of content acquisition and audience preferences. It emphasizes the difficulty of balancing content investment with returns in a competitive market, the high costs associated with marketing, and the need for continuous innovation and adaptation to stay relevant.
The impact of OTT platforms on the Bollywood film industry is significant. The competition for viewers has led to a decrease in cinema ticket sales, affecting the revenue of Bollywood films that traditionally rely on theatrical releases. Additionally, OTT platforms now pay less for film rights due to the uncertain success of films in cinemas.
Looking ahead, the future of OTT in India appears promising. The market is expected to grow by 20% annually, reaching a value of ₹1200 billion by the end of the decade. The increasing availability of affordable smartphones and internet access will drive this growth, making OTT platforms a primary source of entertainment for many viewers.
Top mailing list providers in the USA.pptx
Discover the top mailing list providers in the USA, offering targeted lists, segmentation, and analytics to optimize your marketing campaigns and drive engagement.
Recently uploaded (20)
Organizational Change Leadership Agile Tour Geneve 2024
Organizational Change Leadership Agile Tour Geneve 2024
Zodiac Signs and Food Preferences_ What Your Sign Says About Your Taste
Zodiac Signs and Food Preferences_ What Your Sign Says About Your Taste
LA HUG - Video Testimonials with Chynna Morgan - June 2024
LA HUG - Video Testimonials with Chynna Morgan - June 2024
Training my puppy and implementation in this story
Training my puppy and implementation in this story
Authentically Social by Corey Perlman - EO Puerto Rico
Authentically Social by Corey Perlman - EO Puerto Rico
Dpboss Matka Guessing Satta Matta Matka Kalyan Chart Satta Matka
Dpboss Matka Guessing Satta Matta Matka Kalyan Chart Satta Matka
The Evolution and Impact of OTT Platforms: A Deep Dive into the Future of Ent...
The Evolution and Impact of OTT Platforms: A Deep Dive into the Future of Ent...
Foreign qualified dividends
- 1. Sherayzen Law Office, PLLC sherayzenlaw.com Foreign Qualified Dividends
- 2. Qualified Dividends Equals Lower Income Taxes In U.S. tax law, classification of income plays a very important role in determining your tax liability. “Qualified Dividend” classification is very important because it is subjected reduced tax rates – as low as 15% Qualified Foreign Dividends are eligible for this favorable tax treatment
- 3. History of Qualified Dividends Jobs and Growth Tax Relief Reconciliation Act of 2003 (enacted on May 28, 2003) added section 1(h)(11), which provides that net capital gain for purposes of section 1(h) means net capital gain is increased by “qualified dividend income.” Section 1(h)(11)(B)(I). Qualified dividend income means dividends received during the taxable year from domestic corporations and “qualified foreign corporations.” Certain requirements apply (for example, see holding period requirements of section 1(h)(11)(B)(iii)).
- 4. Qualified Foreign Dividends Foreign Dividend is Qualified Dividend if it meets: Qualified Dividend Requirements + IRC Section 1(h)(11)(C)(i) Tests
- 5. Treaty Test Main Test: Foreign corporation is eligible for benefits under a comprehensive income tax treaty with the United States. The foreign corporation must be a resident within the meaning of such term under the relevant treaty and must satisfy any other requirements of that treaty, including the requirements under any applicable limitation on benefits provision Finally, a treaty test is passed if the treaty is on the list of the U.S. income tax treaties that met the IRC requirements.
- 6. Effective Date of the Treaty It is always important to check the effective dates for each of the treaty for determining when the eligibility for the preferential IRC Section 1(h)(11) arises.
- 7. Other Tests Second Test: If foreign corporation is incorporated in a possession of the United States Third Test: If the stock with respect to which such dividend is paid is readily tradable on an established securities market in the United States. (See Section 1(h)(11)(C)(ii) for more information)
- 8. PFICs and Section 1(h)(11) If foreign corporation is a passive foreign investment company (“PFIC”) as defined in section 1297, its dividends are not eligible for foreign qualified dividend treatment under Section 1(h)(11). See IRC section 1(h)(11)(C)(iii).
- 9. Foreign Qualified Dividends Contact Sherayzen Law Office For Help With Foreign Dividend Planning Go to: http://sherayzenlaw.com