Posts Tagged ‘distributions’

Distributions: Income or capital gains for the shareholder?

August 4, 2011  |  Dividend Taxation  |  No Comments

Preparations for the tea ceremony

A lady tends to the charcoal brazier in preparation for the tea ceremony.

An issue common to many tax systems is whether a distribution made by a company to its shareholders in respect of their shares should be treated as a return of capital to those shareholders or alternatively as an item of income. Shareholder taxation will, of course, often vary dramatically depending on the characterization of such a distribution as an item of income or return of capital. Read More

Deemed dividends – concept, transactions

July 19, 2010  |  Dividend Taxation, Domestic, Featured  |  No Comments

Mount Fuji from the air, of course.

As explained in this post introducing the Japanese Dividends Received Deduction (‘DRD’), Article 23-1 of the Japanese Corporate Tax Law recognises that, in order to mitigate double taxation of corporate profits, certain distributions to shareholders of corporate surplus Read More

Applying tax treaties to TKs

February 14, 2010  |  Tokumei Kumiai  |  No Comments

Interpretation and application of tax treaties to TK contracts.

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