.... . Corporate Dividends: When Taxable .-Rendered in conformity with the be... dividend was likened to a distribution in specie. . Two years later the Court decided Eisner v. Ma...
Transactions that claim inappropriate tax benefits are a perennial problem. When the IRS claims a transaction is abusive, courts generally examine whether the taxpayer had a business purpose and whether the transaction had economic substance (essentially a prospect of profit before taxes). This two-pronged "economic substance doctrine" developed from a series of Supreme Court cases. Unfortunately, the economic substance doctrine provides a poor proxy for the real question, which was the focus of the early cases-whether the claimed tax results are consistent with Congress's intent. One important drawback of the shift from a focus on congressional intent to a focus on the taxpayer's intent and the prospect of pre-tax profit is a doctrine that is much easier for taxpayers to manipulate. T...
... distribution would have constituted a dividend, which would have been taxed in full at ordinary i... consisting of the Monitor shares in specie, on which the taxpayer must pay a surtax calculate...
... of consideration will be treated as a dividend distributed to the individual shareholder and taxe.... In specie distributions of assets whose fair market value ex...
... and without apportionment, a stock dividend made lawfully and in good faith against profits ac... not a stock dividend but a distribution in specie of a portion of the assets of the Union Pacific.' ...
... to procure that the target effects a dividend in specie of shares in a company that owns the unw...
TM Bhd's recent demerger exercise sees all its mobile assets parked under TM International (TMI), which is scheduled for a separate listing on Bursa Malaysia in May next year. While management expects the strategic spin-off to benefit TM, analysts, however, are divided in their views. TA Securities recently downgraded the TM stock to a `sell'. The research house said it was not impressed with TM's core net profit of RM1.58 billion for its third quarter because the actual figure was only RM1.96 million but became inflated mainly due to the disposal of its subsidiary Dialog (in Sri Lanka), listing of subsidiary Spice (India), and reversal of tax provisions.
... return amounting to 9% (including 5% dividend yield).' At the time of writing, the shares were h... strong theme by virtue of the dividend in specie for RegionCo, and/or exposure in the stable recurr...
... net liabilities include net debt, dividends payable, tax liabilities and investments. 3 Except....3 ----- ----- ----- ----- (b) Dividend in specie on demerger of Thus 2002 2001 (pound)m (pound)m De...
... Grenville's existing shareholders as a dividend-in-specie or return of stated or paid up capital. ...
... tax exacted in respect of a certain dividend . [Page 247 U.S. 347, 348]. received by plaintiff...347, 350]. a distribution in specie of a portion of the assets of the Union Pacific, a...
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