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Post-Jgtrra Dividend Planning, Danny A. Pannese, Paul N. Iannone
Post-Jgtrra Dividend Planning, Danny A. Pannese, Paul N. Iannone
Danny Pannese
The JGTRRA reduced the tax rate on dividends for individuals and lowered the accumulated earnings and personal holding company taxes for corporations until 2008. This article reviews some of the planning techniques corporations and shareholders can use to take advantage of the temporarily lower rates. One of the key provisions of the Jobs and Growth Tax Relief Reconciliation Act of 2003 (JGTRRA), if not the prime emphasis of the legislation, is Section 302's reduction in the individual tax rate on corporate dividends received to 15% (5% for individuals in the 15% and 10% brackets). In an emerging trend, the lower …
Liberating Trapped Cash: A Case Study Of Trapped Cash At Apple And Microsoft, Russell P. Engel, Bridget M. Lyons, Danny A. Pannese
Liberating Trapped Cash: A Case Study Of Trapped Cash At Apple And Microsoft, Russell P. Engel, Bridget M. Lyons, Danny A. Pannese
Danny Pannese
The topic of trapped cash, or cash permanently reinvested overseas to avoid tax upon repatriation, has become a hot topic in accounting, finance and policy circles over the past two years. This case study analyzes the activities of two major technology firms, Microsoft and Apple, to liberate enormous holdings of trapped cash. The case prompts a discussion of the topic of trapped cash, stakeholder considerations and tools available to manage cash balances held outside the United States. The focus is to examine the strategies available and those selected by Microsoft and Apple to meet or at least appease stakeholder demands …