Tax

Thomas Cooper quoted in Tax Notes article regarding Trump Tax Returns
September 2020, Tax Notes
MVA Wealth and Estate Planning Associate Thomas Cooper was quoted in a Tax Notes article titled “Trump Tax Returns Call Consulting Fees Into Question” published September 29. Thomas is quoted regarding income tax and transfer tax issues related to the New York Times’ coverage of President Trump’s tax returns.
Proposed Treasury Regulations Impact “Deemed Dividend” Tax Rules in Financing Transactions
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.