The rationale is that under current law, VRP investors which have the virtual assurance of preserving capital and maintaining a under current law, VRP investors, set level of dividend
cash flow, will unfairly receive the economic benefit of equity from an investment that has "non-stock" characteristics.
Certain taxpayers in the insurance industry took the position that the (1) portions of prior CRTC [section]24410 that related to commercial domicile and limited the deduction to insurance company dividends
paid from California-source income were severable from the statute; and (2) remaining portions of pre-AB 263 CRTC [section]24410 provided for a 100% deduction for dividends
received from an 80%-owned insurance company.
The corporation receives a dividend
-received deduction of 100 percent of the deductible dividend
percentage computed in accordance with Sec.
for cash cow Microsoft are easy: The company doesn't need to sink all of its earnings into R&D or acquisitions.
In mid-'99, Applied Signal Technology, a Sunnyvale, CA, maker of digital signal processing equipment for the defense industry, paid its first dividend
of 25 cents per share annually.
It's not surprising that some of the biggest, most established firms have a history of rising dividend
The proposed elimination of the dividend
offset option seems to stem from a belief that recent changes in transfer pricing documentation requirements will soon eliminate the need for section 482 adjustments.
It accomplishes this by stating that no DRD will be allowed for dividends
on stock not held for more than 45 days during the 90-day period beginning on a date that is 45 days before the "ax-dividend
" date (the dine of demarcation for dividend
The initial 1993 policy year dividend
declaration anticipates an average return to policyholders of 17 percent.
Although management is cautiously optimistic that operating profitability can be reinstated in 2007, the immediate reinstatement of dividend
payments remains uncertain.
965(b)(1) limits the dividend
amount eligible for the repatriation DRD.
That is, corporate taxpayers were allegedly not entitled to any relief with respect to the taxes they had overpaid in the past as a result of New Mexico's unconstitutional scheme for taxing dividend
Corporate shareholders historically have preferred dividend
treatment because of the availability of the corporate dividends
-received deduction (DRD).
This represents a 5% increase in real terms over the annual dividends
paid in respect of 1992 Realized Net Income, in line with the Company's 1993 dividend
The pro rata dividend
declaration is contingent on the completion of the merger prior to the next regularly scheduled dividend
record date for Peoples Energy, which is March 22, 2007.