ISDA's Comment Letter on Section 871(m) of the Internal Revenue Code of 1986
March 25, 2011
The North American Tax Committee of ISDA has published a comment letter on selected issues relating to regulations to be issued by the Treasury Department pursuant to Section 871(m) of the Internal Revenue Code of 1986, as amended. The NATC's primary concern is the manner in which the Treasury may define the categories of transactions that are treated as specified notional principal contracts ("SNPCs") and that will be subject to withholding taxes on "dividend equivalent payments."
Cross References
Section 871(m) of the Internal Revenue Code of 1986, as amended