Fruit and tree doctrine will help you identify who is obligated to pay the tax:
- Income from personal services is taxable to who performs the services
- Income from property is taxable to the owner of the property
- Interest income accrues daily—allocate interest income based on the number of days
- Dividends: taxed to the party who is entitled to receive them
Dividends on stock transferred as gift between declared and record dates is generally taxed to the donor
- Dividend tax relief
Exception: dividend from certain foreign corporations (for most situation), from tax-exempt entities, do not satisfy the holding period requirement.
PSQ
Source: http://www.irs.gov
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