U.S. Treasury proposal clarifies withholding on dividend-linked payments
24 December 2013
On 4 December 2013, the IRS issued proposed regulations clarifying the circumstances under which certain payments linked to US-source dividends under a notional principal contract or an equity-linked instrument will be subject to US withholding tax.
At the same time, the IRS issued financial regulations that provide a two-year relief period for parties adapting to this new withholding regime, which is due to become effective in 2016.
Read the full article written by Craig Cohen and Caroline Lapidus of Allen & Overy here. This article has been reproduced from Practical Law Tax with the permission of the publishers. For further information visit www.practicallaw.com or call 020 7202 1200.