U.S.A.: IRS issued Final and Temporary Regulations on Dividend Equivalent payments from U.S. sources

The U.S. Internal Revenue Service (IRS) issued Final and Temporary Regulations on Dividend Equivalent payments from U.S. sources TD 9815 on 19 January 2017. The purpose of the document is to provide guidance for:

• Non-resident alien individuals and foreign corporations that hold certain financial products providing for payments that are contingent upon or determined by reference to U.S. source dividend payments;
• Withholding agents that are responsible for withholding U.S. tax with respect to a dividend equivalent; and
• Other parties to section 871(m) and their agents.

These Regulations are effective on 19 January 2017 and are scheduled to be published in the Federal Register on 24 January 2017.

Further information

For further information, please contact the Clearstream Banking¹ Tax Help Desk, Clearstream Banking Client Services or your Relationship Officer.

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1. Clearstream Banking refers collectively to Clearstream Banking S.A., registered office at 42, avenue John F. Kennedy, L-1855 Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B-9248, and Clearstream Banking AG (for Clearstream Banking Frankfurt (CBF) customers using CreationOnline), registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany and registered in Register B of the Amtsgericht Frankfurt am Main, Germany under number HRB 7500.