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Proposed Treasury Regulations Impact “Deemed Dividend” Tax Rules in Financing Transactions
Randy J. Clark, Robert (Rob) A. Fisher
November 2018

Following tax reform at the end of 2017, cash dividends from a foreign corporate subsidiary to a domestic corporate 10 percent shareholder are exempt from U.S. income tax because the shareholder is permitted a “dividends-received deduction” equal to the amount of the dividend. However, this new deduction was not expanded to cover “deemed dividends” from foreign corporate subsidiaries under Section 956 resulting from full pledges of the stock of, or guarantees by, such foreign corporate subsidiaries. As a result, loan security arrangements for U.S. borrowers that have foreign corporate subsidiaries have continued to be driven by the Section 956 “deemed dividend” rules, and credit agreements have continued to include “deemed dividend”-driven restrictions.


The limited role of privacy concerns in Direct Marketing Association v. Brohl
Rachel W. Coyne
December 2014, Westlaw Journal Computer & Internet

Taxation Counsel Julie Bradlow and Taxation Member Rachel Coyne authored an article published in Westlaw Journal on December 18.


SALT Newsletter
Taxation Group
October 2010

The Taxation Team has released its inaugural state and local tax ("SALT") newsletter. This newsletter highlights recent developments in North Carolina and South Carolina tax law.


IRS Announcement of Qualifying Advanced Energy Project Program
Sprunger & Joyner
August 2009, Energy Update

The Treasury Secretary and the Internal Revenue Service announced the establishment of the qualifying advanced energy project program to implement the new investment credit under Section 48C of the Internal Revenue Code.


Grants in Lieu of Credits
Sprunger & Joyner
July 2009, Energy Update

The Treasury Department and the Department of Energy announced that they are now accepting applications for grants in lieu of production tax credits (“PTCs”) and investment credits for specified energy properties.


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