Capital Markets Tax Quarterly - January 2020

Mayer Brown
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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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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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