US tax rules attacked by equity derivatives dealers

Testing criteria for equity-linked products branded a “joke”

US Section 871(m) reforms branded "unworkable"

New US regulations changing the tax treatment of equity derivatives and equity-linked structured products have been branded a "joke" and "unworkable" by dealers.

The US Internal Revenue Service (IRS) published final and temporary regulations under Section 871(m) of the Internal Revenue Code on September 17. These subject financial products that provide payments linked to dividends from sources within the US to a 30% withholding tax when paid to a non-US investor.

The rules capture listed options

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