Tag: qualified dividend

“Qualified Dividend Income”: How do the Rules Apply to “Controlled Foreign Corporations?” (Part II)

As will be recalled from the previous blog posting discussing the basics of so-called "Controlled Foreign Corporations" (CFC), a United States shareholder of a CFC can possibly be treated as having received “dividend” income at various times. These are when the US shareholder has (i) current income inclusions from the CFC under the anti-deferral regime (Subpart F … Continue reading “Qualified Dividend Income”: How do the Rules Apply to “Controlled Foreign Corporations?” (Part II) →

“Qualified Dividend Income”: How do the Rules Apply to “Controlled Foreign Corporations?” (Part I)

Today’s post continues to explore the interplay between foreign corporations and the US shareholder’s ability for lower tax rates available only for "qualified dividends".  It's a complicated topic. Not all dividends are treated the same and the nuances can make a big difference to the taxpayer’s ultimate investment return. As detailed in my earlier blog … Continue reading “Qualified Dividend Income”: How do the Rules Apply to “Controlled Foreign Corporations?” (Part I) →

Dividends Paid by Foreign Corporations – Are they “Qualified” & Eligible for Capital Gain Rates?

In IRS Notice 2024-11, the Internal Revenue Service (IRS) updated the list of treaties that can provide a foreign corporation with the special status of being a “qualified foreign corporation” (QFC).  The list was updated to include the treaty with Chile, which entered into force on December 19, 2023, and to remove the treaty with … Continue reading Dividends Paid by Foreign Corporations – Are they “Qualified” & Eligible for Capital Gain Rates? →

Dividends from Foreign Corporations Part III – “Controlled Foreign Corporations”

Learn about the interplay between foreign corporations and eligibility for lower tax rates available only for "qualified dividends".  It's a complicated topic and all of the posts in the series should be read in order to understand the ramifications. Part I, Part II and below, Part III.  Unsurprisingly, many US owners of corporations that are … Continue reading Dividends from Foreign Corporations Part III – “Controlled Foreign Corporations” →