ence. The 2015 final regulations provided that a withholding agent who made a payment of a dividend to a qualified intermediary acting a was not required to withhold on that payment if the …

2016年12月13日 · Section 871 (m) treats payments on certain financial instruments as "dividend equivalent payments" with a US source. As a result, the payments are treated like dividends …

Section 871 (m) imposes a 30 percent withholding tax on dividend equivalent payments that are made or deemed to be made to non-U.S. persons with respect to certain derivatives that reference equity (“Equity Derivatives”) of a U.S. issuer.

Notice 2022-37 extends a phase-in period that previously had been provided for certain provisions of the Section 871 (m) Regulations and permits withholding agents to apply the transition rules …

A QDD must provide a valid Form W-8IMY to a withholding agent certifying that it is a QDD, and the withholding agent is not required to withhold on any payment with

根據美國國內稅務局 (IRS)發佈的871 (m)章節稅務新規，持有美股掛鉤金融衍生品（包括差價合約）的外國人也必須像持有真實美股的外國人一樣繳納股息稅。 為避免繳納過多股息稅，您需填寫一份簡短表格。 為何選擇IG交易美股？ 了解新規及其影響…… 871 (m)新規究竟是什麼？ 哪些產品會受影響？ 適用於哪些倉位？ 您需要做什麼？ 871 (m)新規究竟是什麼？ 根據美國國內稅務局 (IRS)發佈的871 (m)章節稅務新規，持有美股掛鉤金融衍生品（包括差價合約）的外國人也必 …

2024年5月23日 · As background, Section 871 (m) and the Regulations treat “dividend equivalents,” paid or deemed paid under certain contracts, as US source dividends that are subject to withholding tax if deemed paid to a non-US person.

We determine when an equity derivative is in scope/subject to Section 871 (m) and calculate the dividend equivalent amounts. Unlike other service providers, our solution also drills down to …

4. If this security is treated as a “section 871(m) transaction”, issuer, acknowledges and agrees to DTC’s request under Treasury Regulation 1.871-15(p)(1) that the Issuer or its agent will …

2010年6月14日 · section 881 for the difference. The 2015 final regulations provided that a withholding agent who made a payment of a dividend to a qualified intermediary acting as a …