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Tax Court recharacterizes preferred equity as debt in Hewlett-Packard case

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • July 9 2012

In Hewlett-Packard Co. v. Commissioner, the Tax Court recharacterized preferred equity owned by Hewlett-Packard Co. (“HP”) in a Dutch corporation as indebtedness and denied HP foreign tax credits and a capital loss on the exit transaction

IRS releases field attorney advice disallowing benefits of a dividends-received deduction transaction

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • April 30 2012

In our last issue of Tax Talk, we highlighted a Chief Counsel Advice Memorandum in which the IRS argued that cumulative preferred stock was Section 1504(a)(4) preferred stock because a payment of unpaid accumulated dividends upon redemption at maturity was not an “unreasonable redemption premium.”

IRS technical advice: cumulative preferred stock that pays accumulated dividends at redemption is Section 1504(a)(4) preferred stock

  • Morrison & Foerster LLP
  • -
  • USA
  • -
  • February 2 2012

A corporate taxpayer is generally entitled to a 70 percent dividends-received deduction with respect to dividends received from a domestic corporation

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