U.S.A.: Notice 2016-76: Guidance issued on payment of dividend equivalents from US sources
The US Internal Revenue Service (IRS) issued Notice 2016-76 on 2 December 2016 to provide guidance on the final and temporary regulations issued under sections 871(m), 1441, 1461 and 1473 of the US Internal Revenue Code (IRC) (collectively referred to as Section 871(m) regulations) for 2017 and 2018.
Notice 2016-76 provides for the phased-in application of the section 871(m) regulations that were finalised in 2015. Among them, section 871(m) regulations will only apply to delta-one transactions (that is, transactions that have a delta of one) in calendar year 2017, and to non-delta-one transactions beginning in calendar year 2018.
We will continue to monitor the situation and will provide further information as it becomes available.
This Taxflash is intended to provide customers with general information gathered from different sources that are generally believed to be reliable. Clearstream Banking S.A. does not guarantee the accuracy or completeness of the information and does not undertake to keep it up to date. Use of the information made available in this Taxflash is at the customer’s own risk and Clearstream Banking S.A., its subsidiaries and affiliates expressly disclaim any liability for any errors or omissions reflected herein. The information in this Taxflash does not constitute legal or tax advice. |