DC is preparing to distribute cash dividends to its shareholders. Must it w/h tax under sec...

80.2K

Verified Solution

Question

Accounting

DC is preparing to distribute cash dividends to itsshareholders. Must it w/h tax under sec 1441 from thedividends?
(a) Shareholder A is a US citizen who resides in France. Onlyher French address appears in the corporation's books.
see reg 1.1441-1(b)(1), (b)(2)(i), (b)(2)(vii), (b)(3)(i),(b)(3)(iii).
(b) Shares of Shareholder B, a citizen and resident of France,are held by a New York broker and are registered in the name of anominee corporation of the broker.
For the w/h obligation generally, see reg 1.1441-1(b)(1),(b)(2)(i), (b)(2)(ii). For w/h at treaty rates, see reg.1.1441-1(e)(1)(ii)(A)(1), (e)(2), -6(a), (b)(1), (b)(3), (c)(1),(c)(2).

Answer & Explanation Solved by verified expert

4.0 Ratings (419 Votes)

adjustment of 01258 40 per share for a total increase in value to the bondholder of 5032 CRAs come in various forms The convertible debt of a company may provide for a CRA for any distributions paid whereas a company with a fairly steady distribution history may issue debt providing for a CRA only to the extent that the distributions exceed a specified threshold Under Sec 305c a change in the conversion ratio or conversion price or a similar transaction is treated See Answer

Get Answers to Unlimited Questions

Join us to gain access to millions of questions and expert answers. Enjoy exclusive benefits tailored just for you!

Membership Benefits:

Unlimited Question Access with detailed Answers
Zin AI - 3 Million Words
10 Dall-E 3 Images
20 Plot Generations
Conversation with Dialogue Memory
No Ads, Ever!
Access to Our Best AI Platform: Flex AI - Your personal assistant for all your inquiries!

Become a Member