The National Law Forum

The Blog of the The National Law Review

Category Archives: Uncategorized

Happy Independence Day!

Happy 4th of July! From your friends at the National Law Review

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Retroactive Tax Planning Re: U.S. Shareholders of Foreign Corporations

Converting Subpart F Income into Qualified Dividends U.S. shareholders of foreign corporations are generally not subject to tax on the earnings of such corporations until the earnings are repatriated to the shareholders in the form of a dividend.  Moreover, when a foreign corporation is resident in a jurisdiction with which the United States has a …

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