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Understanding Newly-Proposed Section 871(m) Dividend Equivalent Amount Rules

Friday, May 16, 2014 12:00 PM to 1:00 PM
Boston Bar Association - 16 Beacon Street, Boston, MA


Section 871(m) of the Internal Revenue Code treats “dividend equivalent amounts” from certain specified swaps and equity-linked instruments as U.S. source income subject to withholding if paid to a non-U.S. person. The Treasury has been attempting to draft rules that would define what types of swaps and equity-linked instruments would be impacted by these rules and provide further guidance on determining the dividend equivalent amount.

After withdrawing an initial set of proposed rules that were issued in 2012, the Treasury issued a new set of proposed Section 871(m) regulations in December 2013. This brown bag is intended to be a discussion of the current developments under Section 871(m), focusing on the newly proposed regulations.

Sponsoring Section/Committee(s):


  • Peter Fucci
  • Laura M. Thompson
  • David A. Oliphant
  • Nelson Suit
    • Burt, Staples & Maner, LLP



Elizabeth Vincensi


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