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Author: billjam Big red star, 1000 posts Old School Fool Add to my Favorite Fools Ignore this person (you won't see their posts anymore) Number: of 76399  
Subject: Growing Trend to Become Foreign Corporations Date: 6/17/2014 11:03 AM
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I posted this on Tax Strategies but it's just as relevant here:

You're probably wondering what this has to do with personal taxes. I would too except my largest stock position is AMAT in an IRA account. Buried in the 500 page prospectus for the merger with a Japanese company and subsequent conversion of the new entity to a Dutch company is something that should concern individual investors in the US.

First, the conversion to shares of the new Dutch company will be taxable as a capital gain for individual US shareholders. Okay, my shares are in an IRA so I'm sheltered from that tax bill, but read on.

Second issue, dividends and other cash distributions paid by the new Dutch company may be subject to a 30% Dutch withholding tax. My only experience with something like this has been some Canadian stock I held. Dividends were subject to 15% Canadian withholding. It couldn't be recovered. I couldn't claim credit against US taxes because it was in my IRA. IOW, I lost 15% of my dividends, which in the US would not have been taxed until I withdrew funds from the IRA.

Today I see another large company talking about incorporating overseas, this one in Ireland. I don't know what the Irish rules are on dividend withholding but stockholders ought to be warned.

This is a growing issue which our Congress keeps ignoring. Meanwhile these companies are going to dodge US taxes and in some cases individual shareholders are going start paying foregin taxes. Congress could fix this but they are too busy doing nothing and blaming each other for their lack of action.
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