Final regulations and removal of temporary regulations.
Category
tax-irs
Sub-agency
IRS
Publication date
2013-12-05
Effective date
2013-12-05
Treasury docket
TD 9648
Abstract
This document contains final regulations relating to certain dividend equivalents for purposes of section 871(m) of the Internal Revenue Code (Code). The regulations provide guidance to nonresident alien individuals and foreign corporations that hold specified notional principal contracts providing for payments that are contingent upon or determined by reference to U.S. source dividend payments and to withholding agents.