The New Participation Exemption: An Opportunity to Convert Ordinary Dividends into Qualified Dividends


Steven Hadjilogiou and Michael Bruno authored this bylined article about the participation exemption under the Tax Cuts and Jobs Act. “U.S. individuals and U.S. trusts that own interests in foreign corporations . . . may find the participation exemption to be especially useful to the extent they own at least 10 percent of the shares in a foreign corporation located in a jurisdiction that does not have an income tax treaty with the United States,” they wrote.