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Rev Proc 96 30 Form

Rev Proc 96 30 Form

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Instructions and help about Rev Proc 96 30

in revenue ruling 89 10 1 cor p on a hundred percent of corp FX which in turn on one hundred percent of quark FY when corp FY paid a dividend up to corp FX country d imposed it withholding tax of 25% on the dividend however if corp FY were to pay dividends directly to corp p the country d dividend withholding tax would only be imposed at a rate of fifteen percent corporate PE wanted to change the structure so that it owned the shares of corp FY directly and could benefit from the lower dividend withholding tax rate to make this change corp FX distributed the shares of corp FY up to court p and a spin-off transaction to qualify for a spin-off under section 355 there must be a valid business purpose the ruling held that a substantial reduction in the amount of foreign withholding tax imposed was a valid business purpose under section 355

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