Single-stock futures alternative to section 871(m) withholding
Nicolas Billeaud, head of portfolio finance solutions at Light Horse Market Solutions, says single-stock futures are set to become the only tax-efficient alternative to counteract US dividend tax withholding under the Hire Act
On January 8, 2013, Mark Pierwien, special counsel to associate chief counsel (financial institutions and products) at the Internal Revenue Service (IRS) told the New York State Society of Certified Public Accountants’ conference that proposed section 871(m) regulations would be vastly simplified.
Section 871(m) was enacted as part of the Hiring Incentives to Restore Employment (Hire) Act, and provides that dividend-equivalent payments to foreign entities will be treated as a dividend from
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