International Taxation

Cummings, Jack; Rowe, Kevin
November 2005
Corporate Business Taxation Monthly;Nov2005, Vol. 7 Issue 2, p9
Trade Publication
The article discusses the United States Internal Revenue Service's release of more guidance under the Internal Revenue Code Section 965 dividends received deduction enacted in the American Jobs Creation Act of 2004. It discusses the background of Code Section 965. Notice 2005-38 deals with the base amount and the cap on extraordinary dividends, particularly in the context of mergers and acquisitions and consolidated returns.


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