Law360, New York (July 15, 2015, 10:15 AM EDT) -- Dividends generally are taxed at ordinary income rates (up to 39.6 percent for individuals). Qualified dividends derived by individuals, however, are taxed at the preferential rate applicable to capital gains (usually 20 percent).[1] Generally, all dividends paid by a domestic corporation are qualified dividends. Dividends paid by a foreign corporation, however, must meet certain requirements in order to be considered qualified and, thus, entitled to favorable tax rates in the hands of individual payees. This article discusses certain dividend planning opportunities and considerations to be taken into account in connection with the initial public offering of a foreign corporation, including the surprising position of the Internal Revenue Service related to dividends on shares of a foreign public company that are not registered under the Securities Act of 1933....