Withholding Tax Dividends

News & Analysis as of

US Withholding Tax on Dividend Equivalent Payments Under Swaps

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

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

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

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

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

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

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

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

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

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

Legal Alert: The Cliff-Hanger (Chapter One) is Over: Highlights of the American Taxpayer Relief Act of 2012

On January 2, 2013, President Obama signed into law the American Taxpayer Relief Act of 2012 (the Act), effective as of January 1, 2013. In general, the Act made permanent for most taxpayers the tax rate cuts first enacted...more

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