70) The resulting current net tax cost of a dividend
to a corporate taxpayer will be either 10.
For example, presume a taxpayer received a $1,000 dividend
in 1988 from a corporation in which they held a 10 percent ownership interest.
Given its rich cash position, a dividend
-paying firms spread their profits around and generate regular income for shareholders, their shares are generally less volatile than those of companies that don't give dividends
If a section 482 adjustment were subsequently made, the resulting interest and penalties could prove onerous to the taxpayer in the absence of the dividend
State Fund also announced that 100% of the initial dividend
calculation for 1993 would be paid to policyholders.
Therefore, you will not be receiving 1099 Dividend
information from your broker or the Company's transfer agent, Computershare.
corporation that is not very large, a $500 million upper limit may be more than enough to cover any level of dividend
that the taxpayer might receive.
The Department made a third argument with respect to taxpayers like Conoco and Intel that had sought to exclude federal Subpart F income and PFIC income on the same basis as actual repatriated foreign dividend
income was excluded.
Observation: Corporations will have less (or no) incentive to earn reorganization boot dividends
because-- as extraordinary dividends
--the income will give rise to stock basis reductions measured by the DRDs when the dividends
Payment of the dividend
will be made on May 12, 1994 and May 26, 1994 in Chile and the United States, respectively, to shareholders of record on May 6, 1994.
As previously announced, it is intended that the quarterly dividend
of the combined company (which will be called Integrys Energy Group, Inc.