"IRS Releases Final and Proposed Regulations Regarding Dividend Equivalent Payments to Foreigners"
By EsqSocial Corporation 16/12/13
As part of 2010 legislation, Congress enacted section 871(m) of the Internal Revenue Code, which provides that payments made to foreign persons under specified notional principal contracts (“Specified NPCs”), securities loans, sale-repurchase...
By: Skadden, Arps, Slate, Meagher & Flom LLP