News & Analysis as of

Section 871(m) Dividends

Cadwalader, Wickersham & Taft LLP

IRS Kicks Substantial Equivalence Test Down the Road Again

On May 22, 2024, the IRS issued Notice 2024-44, which once again extends the phase-in for Section 871(m) withholding.  Broadly speaking, foreign persons may be subject to a 30% withholding tax under Section 871(m) on certain...more

Mayer Brown

Section 871(m) and BEAT Qualified Derivative Payment Reporting Phase-Ins Extended Two More Years

Mayer Brown on

On May 22, 2024, the US Department of Treasury and the IRS issued two important notices—one delaying the full implementation of the withholding rules on dividend equivalent payments, and the other on derivative reporting for...more

Kramer Levin Naftalis & Frankel LLP

New Treasury Regulations and IRS Notice Regarding Withholding on Dividend Equivalent Payments to Foreign Holders

On Dec. 16, the Internal Revenue Service (IRS) issued final regulations (the new regulations) governing a narrow aspect of rules applicable to withholding on “dividend equivalent payments” made to foreign persons. The new...more

Akin Gump Strauss Hauer & Feld LLP

U.S. Withholding on Synthetic Trades over U.S. Equities (Section 871(m)) – Additional Delay of Full Implementation until 2023

• The broader application of Section 871(m) has again been delayed, this time until January 1, 2023 and as a result, investment funds with non-U.S. feeders or investors up the chain should generally expect to incur U.S....more

Morrison & Foerster LLP

MoFo Tax Talk: Volume 9, Issue 4

EDITOR’S NOTE - Tax Talk doesn’t remember much about 1985. But we do remember that, after Ronald Reagan was re-elected president in 1984, tax reform was a very hot topic (remember the Tax Reform Act of 1985?). Anyway,...more

Orrick, Herrington & Sutcliffe LLP

Derivatives In Review - January 2017

Regulation AT – An Update - From the time Regulation AT was initially proposed by the CFTC over a year ago, the CFTC has solicited and considered numerous comment letters, held a public roundtable, supplemented the...more

Orrick, Herrington & Sutcliffe LLP

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

Dechert LLP

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

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

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