News & Analysis as of

Derivatives Withholding Requirements

Cadwalader, Wickersham & Taft LLP

Proposed QI Agreement Addresses Cascading Withholding on Dividend Equivalents

On July 1, the U.S. Internal Revenue Service issued Notice 2016-42, which proposes changes to the qualified intermediary (QI) agreement to address cascading U.S. withholding tax on dividends and “dividend equivalents”...more

Cadwalader, Wickersham & Taft LLP

New 871(m) Regulations Finalize Dividend Equivalent Payment Withholding Rules for Equity Derivatives

On September 17, 2015, the IRS and the Treasury Department issued final, temporary, and proposed regulations under section 871(m) of the Internal Revenue Code (collectively, the “new regulations”) that provide the rules for...more

Orrick, Herrington & Sutcliffe LLP

IRS Issues Final Regulations and New Proposed Regulations Regarding Withholding on Derivatives on U.S. Stocks

On December 5, 2013, the Internal Revenue Service ("IRS") issued final regulations (the "Final Regulations") and proposed regulations (the "2013 Proposed Regulations") under section 871(m), which address withholding on...more

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