Taxation of regulated investment companies and their shareholders / Richard M. Hervey, Esq. (Dechert LLP, New York, New York).
2008
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Details
Author
Title
Taxation of regulated investment companies and their shareholders / Richard M. Hervey, Esq. (Dechert LLP, New York, New York).
Former Title
Taxation of regulated investment companies <apr. 28, 2008>
Added Corporate Author
Imprint
[Arlington, Va.] : Bureau of National Affairs, [2008]-
Description
1 online resource.
Frequency
Updated irregularly.
Series
Tax management portfolios ; 740-3rd.
Formatted Contents Note
Detailed analysis. Introduction
Historical background
Types of entities that can qualify for RIC status
Election of RIC status
Qualifying income requirement
Diversification requirements
Minimum distribution requirements for taxation of RICs as conduits under subchapter M
General tax treatment of qualifying RICs
Conduit treatment of long-term capital gains
Conduit treatment of tax-exempt interest income, [section] 852(b)(5)
Conduit treatment of foreign tax credit [section] 853
Conduit treatment of credits on tax credit bonds
Conduit treatment of dividends received deduction and qualified dividend income, [section] 854
Section 852(b)(7), dividends paid in January that are declared in the prior calendar quarter
Dividends paid by a RIC after the close of taxable year, [section] 855
Deficiency dividends, [section] 860
Excise tax on failure to satisfy calendar year minimum distribution requirements, [section] 4982
Taxation of shareholders of RICs
Treatment of foreign shareholders in RICs
Series funds
Master-feeder structures
Funds of funds
Exchange traded funds (ETFs)
Disallowance of indirect deductions by shareholders for certain expenses of non-publicly offered RICs
Special rules applicable to subchapter C corporations electing RIC status and to transfers of property from subchapter C corporations to RICs
Former "short short" test under former [section] 851(b)(3)
Working papers.
Historical background
Types of entities that can qualify for RIC status
Election of RIC status
Qualifying income requirement
Diversification requirements
Minimum distribution requirements for taxation of RICs as conduits under subchapter M
General tax treatment of qualifying RICs
Conduit treatment of long-term capital gains
Conduit treatment of tax-exempt interest income, [section] 852(b)(5)
Conduit treatment of foreign tax credit [section] 853
Conduit treatment of credits on tax credit bonds
Conduit treatment of dividends received deduction and qualified dividend income, [section] 854
Section 852(b)(7), dividends paid in January that are declared in the prior calendar quarter
Dividends paid by a RIC after the close of taxable year, [section] 855
Deficiency dividends, [section] 860
Excise tax on failure to satisfy calendar year minimum distribution requirements, [section] 4982
Taxation of shareholders of RICs
Treatment of foreign shareholders in RICs
Series funds
Master-feeder structures
Funds of funds
Exchange traded funds (ETFs)
Disallowance of indirect deductions by shareholders for certain expenses of non-publicly offered RICs
Special rules applicable to subchapter C corporations electing RIC status and to transfers of property from subchapter C corporations to RICs
Former "short short" test under former [section] 851(b)(3)
Working papers.
Summary
" ... discusses in detail the provisions of [section] 851-[section] 855, [section] 860 and [section] 4982 of the Internal Revenue Code, which govern the taxation of regulated investment companies (RICs). The Portfolio also discusses the applicability of other Code provisions to RICs."
Bibliography, etc. Note
Includes bibliographical references.
System Details Note
Mode of access: World Wide Web.
Source of Description
Description based on contents viewed on December 8, 2015; title from description page.
Location
www
Available in Other Form
Print version: Hervey, Richard M. Taxation of regulated investment companies and their shareholders. Arlington, VA : Tax Management Inc., ©2015-
Linked Resources
Alternate Title
Tax Management Portfolios.
Language
English
Record Appears in