News & Analysis as of

Withholding Tax Dividends

The Netherlands - Budget 2018 - Dividend withholding tax and non-resident taxation

by Dentons on

On 19 September 2017, the Dutch government released the State’s Budget for the year 2018. The Budget includes a draft bill to expand the dividend withholding tax exemption to tax treaty countries, to introduce a withholding...more

New guidance to register as “privileged” domestic or foreign investment fund under German investment taxation law

by Dechert LLP on

Pursuant to the new German investment tax act (GITA) that will take effect of 1 January 2018, domestic and foreign resident investment funds may become subject to German corporate income tax with various German source income...more

The Netherlands proposes changes to dividend withholding tax

by DLA Piper on

The Dutch government has released an attractive proposal to fully exempt withholding tax on dividends paid to non-resident shareholders in treaty countries provided certain conditions are met. Many multinational enterprises...more

Development of court practice of determining direct capital investment for the purpose of applying the 5% withholding tax rate...

by Dentons on

On 3 May 2017 the Commercial Court of Chelyabinsk Region rendered a decision in case No. ?76-20508/2016 under the claim of Chelyabenergosbyt PJSC (the “Company”)....more

Budget 2017

by Hogan Lovells on

The 2017 Budget was presented by Minister Pravin Gordhan before Parliament on 22 February 2017. The 2017 tax proposals are projected to raise ZAR28 billion, and increase the tax burden from 26% of GDP in 2016/17 to 26.7%...more

IRS Releases Transition Guidance for the Dividend Equivalent Rules

On December 2, 2016, the Internal Revenue Service (the “IRS”) issued Notice 2016-76 (the “Notice”), which provides highly anticipated guidance regarding “dividend equivalent” payments under section 871(m) of the Internal...more

Much-Anticipated Section 871(m) Dividend Equivalent Guidance Provides Promised Transition Relief

by Dechert LLP on

The U.S. Internal Revenue Service (the “IRS”) has released Notice 2016-76, providing anticipated guidance and transition relief for certain dividend equivalent transactions described in section 871(m) of the U.S. Internal...more

IRS Phases in Section 871(m) Dividend Equivalent Withholding

On December 2, the U.S. Internal Revenue Service issued Notice 2016-76, which phases in the application of withholding on dividend equivalent payments under section 871(m). Under the notice, withholding applies only to...more

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

Potential tax consequences of Brexit from a German perspective

by Reed Smith on

On 23 June, the UK is holding a referendum to decide whether it should leave or remain in the European Union. A vote to leave the EU (the so-called Brexit) would not only have repercussions from a tax perspective for the UK....more

Treasury Targets Related-Party Debt with Proposed Regulations to Treat Debt as Equity

by Latham & Watkins LLP on

Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt. On April 4, 2016, the US Department of the Treasury (Treasury) and the...more

European M+A News, Winter 2016

by Morrison & Foerster LLP on

Smart Acquisition Structures For Deals In Germany And The UK - What Are the Criteria for Smart Acquisitions via Corporations? - Inbound investment structures seeking to acquire a German or UK corporation should take...more

MoFo Tax Talk - Volume 8, No. 4

by Morrison & Foerster LLP on

IRS PROVIDES RICS ALTERNATIVES TO ACCOUNT FOR FOREIGN TAX REFUNDS - Generally, when a U.S. taxpayer pays foreign tax, the U.S. taxpayer is entitled to take a credit (a “Foreign Tax Credit”) against the taxpayer’s U.S....more

US Withholding Tax on Dividend Equivalent Payments Under Swaps

by Katten Muchin Rosenman LLP on

The US Department of the Treasury has issued regulations with respect to withholding on “dividend equivalent” payments made to a non-US long party on swaps and other financial instruments that are linked to US equities. These...more

Corporate and Financial Weekly Digest - Volume X, Issue 40

by Katten Muchin Rosenman LLP on

BROKER-DEALER - FINRA Requests Comment on Revised Price Disclosure Information Standards for Corporate and Agency Debt Securities - The Financial Industry Regulatory Authority issued a regulatory notice...more

Final Regulations Under Section 871(m) Clarify Withholding Tax Rules for Equity-Linked Derivatives, Yet Many Challenges Remain

by Shearman & Sterling LLP on

On September 17, 2015, the Treasury Department and the Internal Revenue Service (the “IRS”) issued new temporary and final regulations under section 871(m) of the Internal Revenue Code regarding the imposition of US federal...more

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

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, and Some Ugly

by Morrison & Foerster LLP on

On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m), the Internal Revenue Code provision that treats “dividend equivalents” paid under certain contracts as...more

German Investment Taxation – Reform Ahead

by Dechert LLP on

The German Ministry of Finance (Bundesfinanzministerium) circulated a discussion draft bill on the reform of fund taxation (‘Draft Bill’) on 22 July 2015. The Draft Bill contains significant changes to the German tax...more

Tax Measures in the UK 2015 Summer Budget

by Morgan Lewis on

The new tax announcements are designed to improve productivity and correct imbalances in the tax system. On 8 July, UK Chancellor of the Exchequer George Osborne made a number of announcements relating to the tax system...more

Potential refund of Swedish withholding tax: opportunity for US RICs

by DLA Piper on

In 2012, the Swedish Administrative Court of Appeal concluded that Sweden’s withholding tax rules are not compatible with EC law when Swedish withholding tax is levied on dividend payments made to a Luxembourg SICAV fund. ...more

IRS Releases Final and New Proposed Regulations That Define “Dividend Equivalent” for U.S. Withholding Tax Purposes

by Morrison & Foerster LLP on

On December 5, 2013, the Internal Revenue Service (“IRS”) finalized temporary regulations and issued new proposed regulations under Section 871(m), the Internal Revenue Code provision that treats “dividend equivalents” paid...more

Final And Proposed Regulations Address U.S. Withholding Tax On U.S. Equity Derivatives

I. Introduction - On Tuesday, December 4, the IRS and the Treasury Department issued proposed regulations that, if finalized as proposed, would dramatically increase the extent to which U.S. withholding tax is imposed...more

2013 Amendments to United States and Japan Income Tax Treaty

by Baker Donelson on

On January 24, 2013, the United States and Japan signed a proposed protocol to amend the existing tax treaty between the two countries, which was entered into in 2003. The amendments, which will take effect when ratified by...more

American Taxpayer Relief Act of 2012 Approved by Congress and Signed by the President

by Dechert LLP on

Summary - President Obama on January 2, 2013 signed into law the American Taxpayer Relief Act of 2012 (the “Act”). The Act extends certain tax rates, tax credits, and other provisions previously enacted by other tax...more

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