Ruling 2005-02: IRC Sec. 965, apportionable business income.The American Jobs Creation Act of 2004 enacted IRC (Internet Relay Chat) Computer conferencing on the Internet. There are hundreds of IRC channels on numerous subjects that are hosted on IRC servers around the world. After joining a channel, your messages are broadcast to everyone listening to that channel. Sec. 965, which provides U.S. companies with a temporary incentive to repatriate repatriate To bring home assets that are currently held in a foreign country. Domestic corporations are frequently taxed on the profits that they repatriate, a factor inducing the firms to leave overseas the profits earned there. any earnings held by foreign subsidiaries. However, a requirement under Sec. 965 that dividends be used in certain types of investments may affect the characterization of any possible income earned on the dividends, pending their use in a qualified investment under Sec. 965. [ILLUSTRATION OMITTED] When is income that is earned on IRC Sec. 965 cash dividends, pending the domestic reinvestment Reinvestment Using dividends, interest and capital gains earned in an investment or mutual fund to purchase additional shares or units, rather than receiving the distributions in cash. 1. In terms of stocks, it is the reinvestment of dividends to purchase additional shares. of those cash dividends under IRC Sec. 965, properly characterized as apportionable Adj. 1. apportionable - capable of being distributed allocable, allocatable distributive - serving to distribute or allot or disperse business income? Legal Ruling 2005-02 provides guidance at www.ftb.ca.gov/law/rulings. |
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