The Internal Revenue Service has released Notice 2010-46, 2010-24 IRB 1, which impacts on the process for withholding and reporting by foreign intermediaries with respect to their payment and receipt of substitute dividend payments on underlying U.S. Securities. Among its' provisions, Notice 2010-46 revokes Notice 97-66, 1997-2 C.B. 328, effective for substitute dividend payments made after September 13, 2010. Following such date, the approcach described in Notice 97-66 for addressing cascading withholding on U.S. source substitute dividends is replaced with revised documentation, withholding and reporting procedures and requirements described in Section II (Proposed Withholding and Reporting Framework) and Section III (Transition Rule) of the notice.
The IRS has directed questions relating to this Notice to QI Program Manager Thomas Chillemi, who can be reached by phone at 212-298-2101 or email at Thomas.Chillemi@irs.gov.
Posted by Joshua Hock, Associate Editor, Wealth Strategies Journal
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