01/25/2012 07:00:00 PM EST
Withholding Tax on Dividend Equivalent Payments: IRS and Treasury Issue Temporary and Proposed Regulations on “Dividend Equivalents” on “Specified Notional Principal Contracts”
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Section 871(m) of the Code requires taxpayers to treat certain “dividend equivalent” payments on “specified notional principal contracts” (“specified NPCs”), among other types of transactions, as U.S.- source dividends
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