Prop. Regs. Apply ‘Delta’ Approach For Dividend-Equivalent Payments To Foreign Persons
By EsqSocial Corporation 29/01/14
Section 871(m) was enacted in 2010 to curb the perceived abuse of foreign persons using derivatives — primarily notional principal contracts (NPCs) or swaps — to replicate the ownership of an underlying U.S. equity without such person being subject...
By: Bilzin Sumberg Baena Price & Axelrod LLP