Section 871(m) of the Internal Revenue Code, enacted in 2010, treats “dividend equivalents” as U.S.-source dividends for withholding tax purposes.  On December 4, 2013, the Treasury Department and the Internal Revenue Service (the “IRS”) released new proposed regulations (the “2013 Proposed Regulations”) and final regulations (the “2013 Final Regulations”) interpreting Section 871(m).

This communication, which we believe may be of interest to our clients and friends of the firm, is for general information only. It is not a full analysis of the matters presented and should not be relied upon as legal advice. This may be considered attorney advertising in some jurisdictions. Please refer to the firm's privacy notice for further details.