IRS Amends Rules to Require Withholding on Dividend Equivalents Paid to Foreigners
We are writing to update you on a tax alert we issued on January 31, 2012, "Treasury issues guidance on withholding on total return swaps". On August 30, 2012, the IRS announced that the transition period extending the statutory definition of a specified notional principal contract (SNPC) is extended for one year through December 31, 2013. The IRS indicated that this extension is offered in order to give taxpayers another year to build the systems required to implement the withholding rules that affect nonresidents holding SNPCs.
For additional information or questions, please contact:
National Managing Partner, Asset Management Tax
Deloitte Tax LLP
+1 212 436 2165