Entergy has earned enough money to cover its dividend payments every quarter for the past five years.

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Given the substantial limitations and restrictions on the ability of plaintiffs to actually demand and receive the dividend and capital gains income that BLMIS reported they had earned, the court concludes that plaintiffs did not and could not constructively receive the money that plaintiffs had reported as income on their GIT returns.

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Before the Bush tax cut, dividends labored under a heavy handicap--they were taxed twice: once when the company earned the money, a second time when the dividend passed into the hands of the investor.

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Upon receiving the dividend, X Co. is permitted to utilize a foreign tax credit to reduce the U.S. tax applied to the dividend, preventing the same income from being taxed twice: once when earned by Foreign Co. and a second time when distributed to X Co.

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