US tax rules attacked by equity derivatives dealers
Section 871(m) reforms designed to prevent avoidance of dividend tax capture the wrong instruments, while the testing criteria are a “joke”
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
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