Searching Content indexed under Withholding Tax by Mark Howe ordered by Published Date Descending.
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Tax Update: IRS Trims Back FATCA
On December 13, 2018, the Internal Revenue Service issued proposed regulations that eliminate certain types of withholding under Sections 1471-1474 of the tax code, which are commonly referred to as FATCA.
United States
20 Dec 2018
IRS Phases In Section 871(m) Dividend Equivalent Withholding
On December 2, the U.S. Internal Revenue Service issued Notice 2016-76, which phases in the application of withholding on dividend equivalent payments under section 871(m).
United States
9 Dec 2016
Application Of New Debt-Equity Regulations To Securitizations
Unlike the proposed regulations issued in April, the new regulations do not apply to debt issued by foreign securitizations that are treated as corporations for U.S. tax purposes, such as most foreign CLOs.
United States
2 Nov 2016
Proposed QI Agreement Addresses Cascading Withholding On Dividend Equivalents
As discussed in a prior Clients & Friends Memo, section 871(m) of the Internal Revenue Code imposes withholding on "dividend equivalents" paid on derivatives that reference U.S. equity securities.
United States
11 Jul 2016
Final And Proposed Regulations Address U.S. Withholding Tax On U.S. Equity Derivatives
On Tuesday, December 4, the IRS and the Treasury Department issued proposed regulations that, if finalized as proposed, would dramatically increase the extent to which U.S. withholding tax is imposed on U.S. equity derivatives.
United States
24 Dec 2013
The Final FATCA Regulations: Applications To Foreign Investment Vehicles
On January 17, 2013, the Internal Revenue Service issued final regulations that provide guidance on the "Foreign Account Tax Compliance Act".
United States
7 Feb 2013
U.S. Treasury Department Releases Model FATCA Intergovernmental Agreements
On July 26, the U.S. Treasury Department released two model intergovernmental agreements that will provide residents of signatory countries with an alternative withholding and reporting regime to that imposed under the "Foreign Account Tax Compliance Act" ("FATCA") provisions contained in sections 1471 through 1474 of the Internal Revenue Code.
United States
15 Aug 2012
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