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U.S. Withholding Tax on Equity Derivatives: Addressing Evolving Regulations under Section 871(m)

Deloitte Dbriefs | Investment Management

Start date and time

January 6, 2014 2:00 PM

End date and time

January 6, 2014 3:00 PM

Time zone:

(GMT-05:00) Eastern Time (US & Canada)

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Host: Ted Dougherty, Partner - Deloitte Tax LLP
Specialized Knowledge & Applications: 1 Intermediate CPE Credit

On December 4, 2013, Treasury and the IRS released new guidance under Section 871(m) of the Internal Revenue Code. It dramatically affects non-U.S. persons and funds trading derivatives that reference stock of U.S. issuers. What are implications for investment managers and how can you prepare? We'll discuss:

  • The current regime, effective until December 31, 2015, and how it applies to total return equity swaps.
  • The new regime, proposed to be effective on January 1, 2016, and the three major tax law changes applying to all equity derivatives that reference U.S. stocks.
  • Identification of dividend equivalent amounts in transactions involving price-only derivatives.

Understand what this evolving regulation could mean for investment management portfolios and hear how you can prepare.

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