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Automatic Exchange of Information (AEoI), Common Reporting Standard (CRS), FATCA
Automatischer Informationsaustausch (AIA)

IRS issues final, temporary, and proposed regulations

6. März 2017
Lesezeit: 1 min
Of Counsel (AIA, CRS, FATCA)

IRS issues final, temporary, and proposed regulations under Sections 871(m) and 1441 dealing with dividend equivalent payments; see link  


There is good news: Section 871(m) will not affect fiduciaries, e.g. Trustees. Section 871(m) and the related regulations have widened the scope of payments that are considered US source payments and are thus subject to US withholding and reporting rules. This implies that clients, also those of fiduciaries (e.g. trustees) are affected more by withholding and reporting than before Section 871(m) entered into force in 2017.

Note: In the last few days there has been a call for a task force organized by the industry that should deal with the implementation of Section 871(m). One will have to find out what the needs and requirements are, come up with solutions and coordinate the implementation. It seems that the industry has reacted accordingly.