Dividend Planning Considerations In Foreign Co. IPOs

Law360, New York ( July 15, 2015, 10:15 AM EDT) -- Dividends generally are taxed at ordinary income rates (up to 39.6 percent for individuals). Qualified dividends derived by individuals, however, are taxed at the preferential rate applicable to capital gains (usually 20 percent).[1] Generally, all dividends paid by a domestic corporation are qualified dividends. Dividends paid by a foreign corporation, however, must meet certain requirements in order to be considered qualified and, thus, entitled to favorable tax rates in the hands of individual payees. This article discusses certain dividend planning opportunities and considerations to be taken into account in connection with the initial public offering of a foreign corporation, including the surprising position of the Internal Revenue Service related to dividends on shares of a foreign public company that are not registered under the Securities Act of 1933....

Law360 is on it, so you are, too.

A Law360 subscription puts you at the center of fast-moving legal issues, trends and developments so you can act with speed and confidence. Over 200 articles are published daily across more than 60 topics, industries, practice areas and jurisdictions.


A Law360 subscription includes features such as

  • Daily newsletters
  • Expert analysis
  • Mobile app
  • Advanced search
  • Judge information
  • Real-time alerts
  • 450K+ searchable archived articles

And more!

Experience Law360 today with a free 7-day trial.

Start Free Trial

Already a subscriber? Click here to login

Hello! I'm Law360's automated support bot.

How can I help you today?

For example, you can type:
  • I forgot my password
  • I took a free trial but didn't get a verification email
  • How do I sign up for a newsletter?
Ask a question!