01/29/2012 07:00:00 PM EST
IRS and Treasury Department Publish Anticipated Guidance on "Dividend Equivalent" Payments Derived from Equity Swap Arrangements
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On January 19, 2012, the U.S Treasury Department ("Treasury") and the Internal Revenue Service ("IRS") issued rules governing when equity swaps and similar transactions would result in imposition of U.S. withholding tax under Section
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