United States:
IRS Extends Effective Date And Phase-In Period For Dividend Equivalent Rules
27 September 2018
Cadwalader, Wickersham & Taft LLP
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The Internal Revenue Service ("IRS") delayed implementing certain rules that are
intended to prevent non-U.S. persons from using derivative
instruments to avoid U.S. withholding tax on U.S. equities.
In Notice 2018-72, the IRS reported that the effective date for
Section 871(m) and the phase-in period in Notice 2016-76 will be delayed. The IRS
previously delayed the effectiveness of these rules by one year
in 2017.
The anti-abuse rule will continue to apply during
the phase-in years.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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