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Feb
On January 19, 2017, the Internal Revenue Service (the “IRS”) issued final, temporary, and proposed regulations (the “Regulations”) under section 871(m) of the Internal Revenue Code of 1986, as amended (the “Code”). Code section 871(m) imposes withholding tax on U.S. source “dividend equivalent” payments made on certain derivative financial products, including notional principal contracts (“NPCs”), equity linked instruments (“ELIs”), and sales-repurchase agreements.
The Regulations serve to both clarify and codify much of the official and regulatory guidance issued under...