On December 16, 2019, the IRS released Notice 2020-2 (the “Notice”), which further extends the phase-in of regulations under Section 871(m) of the Code3 (the “Regulations”)4 and related provisions. Section 871(m) and its regulations generally treat “dividend equivalents” paid (or deemed paid) under certain contracts as U.S. source dividends that are subject to withholding tax if paid to a non-U.S. person.
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