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Foreign Nationals › Dividends › Income Taxes

Bilzin Sumberg

Prop. Regs. Apply ‘Delta’ Approach For Dividend-Equivalent Payments To Foreign Persons

Bilzin Sumberg on

Section 871(m) was enacted in 2010 to curb the perceived abuse of foreign persons using derivatives — primarily notional principal contracts (NPCs) or swaps — to replicate the ownership of an underlying U.S. equity without...more

Patterson Belknap Webb & Tyler LLP

American Taxpayer Relief Act of 2012: Tax Implications for U.S. Taxpayers Living Abroad

Patterson Belknap Webb & Tyler LLP on

Although the American Taxpayer Relief Act of 2012 (“Fiscal Cliff Legislation”) passed last week does not contain any sweeping changes targeted at U.S. taxpayers living abroad, a number of provisions are relevant to such U.S....more

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