News & Analysis as of

Swaps Dividends

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

CFTC Approves Amendments to Rules on Intermediary Registration and Review of Adverse Actions - On January 9, 2018, the U.S. Commodity Futures Trading Commission (the "CFTC") approved final rules that update Parts 3 and 9...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

Katten Muchin Rosenman LLP

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

Katten Muchin Rosenman LLP

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

Cadwalader, Wickersham & Taft LLP

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

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

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