Archive - September 2015
TD 9734: Treasury Releases Final and Temporary Section 871(m) Regulations September 17, 2015
Treasury just released the highly anticipated Section 871(m) regulations. These regulations deal with dividend equivalent payments and are basically a re-souring rule that subjects various derivative instruments to withholding if the holder of the instrument is a foreigner. The newly issued regulations finalize a set of proposed regulations from December 2013, which succeeded another set of proposed regulations from 2012. There was a lot of commentary about the proposed regulations, including on this website, and the overall sentiment was not very positive. Various stakeholders...