Add to ORKGA number of provisions scattered throughout the income tax legislation seek to deal with the evil of dividend stripping (primarily s 177E of ITAA 1936, s 207-145 and 207-150 of ITAA 1997). However nowhere in the legislation is there a definition of dividend stripping. This has been of concern to tax advisers because (in the absence of the availability of the CGT small business concessions) plain vanilla tax planning has traditionally favoured a shareholder who controls a private company with undistributed profits first stripping the profits out of the company by way of a dividend issue before selling the shares. Of course, it all depends on the tax profile of the company and the shareholder bur a scenario can be envisaged whereby the d...
The growth of share repurchasing as an element of financial strategy for large, publicly held corpor...
The growth of share repurchasing as an element of financial strategy for large, publicly held corpor...
Funding for the sale of an interest in a profitable closely held corporation often comes from two so...
A number of provisions scattered throughout the income\ud tax legislation seek to deal with the evil...
Inclusion or exclusion of stock dividends in the scope of income has been an thorny issue in financi...
At issue before the Full Federal Court in Lawrence v FCT was the scope of the operation of s 177E(1)...
A firm\u27s dividend policy reflects management\u27s decision as to what portion of accumulated earn...
This article critically analyses the concept of a dividend in the context of s 44(1) of the Income T...
In 1946 petitioner received a pro-rata dividend of preferred stock of the distributing corporation, ...
Since 1936, the Internal Revenue Code has treated elective stock dividends on common stock, which ar...
This thesis examines recent legislative developments in tax avoidance law, dealing specifically with...
The many recent discussions of the problem of dividend accumulations show that plausible grounds exi...
X corporation had two classes of stock outstanding. The Class A stock was a preferred stock entitled...
The Internal Revenue Service has established a policy of applying the constructive dividend doctrine...
Persons who receive distributions of surplus assets in the liquidation of Australian companies may b...
The growth of share repurchasing as an element of financial strategy for large, publicly held corpor...
The growth of share repurchasing as an element of financial strategy for large, publicly held corpor...
Funding for the sale of an interest in a profitable closely held corporation often comes from two so...
A number of provisions scattered throughout the income\ud tax legislation seek to deal with the evil...
Inclusion or exclusion of stock dividends in the scope of income has been an thorny issue in financi...
At issue before the Full Federal Court in Lawrence v FCT was the scope of the operation of s 177E(1)...
A firm\u27s dividend policy reflects management\u27s decision as to what portion of accumulated earn...
This article critically analyses the concept of a dividend in the context of s 44(1) of the Income T...
In 1946 petitioner received a pro-rata dividend of preferred stock of the distributing corporation, ...
Since 1936, the Internal Revenue Code has treated elective stock dividends on common stock, which ar...
This thesis examines recent legislative developments in tax avoidance law, dealing specifically with...
The many recent discussions of the problem of dividend accumulations show that plausible grounds exi...
X corporation had two classes of stock outstanding. The Class A stock was a preferred stock entitled...
The Internal Revenue Service has established a policy of applying the constructive dividend doctrine...
Persons who receive distributions of surplus assets in the liquidation of Australian companies may b...
The growth of share repurchasing as an element of financial strategy for large, publicly held corpor...
The growth of share repurchasing as an element of financial strategy for large, publicly held corpor...
Funding for the sale of an interest in a profitable closely held corporation often comes from two so...