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September 8, 2010: Association of Global Custodians (AGC)


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Association of Global Custodians (AGC) submitted comments to the Department of the Treasury and to the Internal Revenue Service (IRS).

The AGC, which is an informal group of ten global banking institutions, specifically requested, “guidance clarifying that custodians and other intermediaries that are not parties to the contract are not considered ‘withholding agents’ for purposes of Chapter 3 or Chapter 4 with respect to dividend equivalent payments made pursuant to specified notional principal contracts.” The AGC also noted that they intend to submit a full set of comments in response to Notice 2010-60 prior to the November 1, 2010 deadline.

A copy of the letter, as originally published by Tax Analysts, is attached.

Contact FATCA Leader for further information.

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