On September 17th 2015, the US treasury and IRS issued Final and Temporary regulations under Section 871(m) which requires ‘dividend equivalents’ to be treated as US sourced dividends and therefore subject to the US withholding tax. In this project, we are required to ensure global markets (EQD and PB) compliance with the IRS 871(m) regulation requirements.  The ISDA requires all clients in the 871(m) scope to submit an adherence letter and failure to comply will result in a 30% withholding tax.

Vantage Point have been engaged by a Top Tier European Investment Bank to conduct a review of the requirements of IRS 871(m), define and execute the project plan and ensure full full regulatory compliance. In addition to managing and executing the programme, Vantage Point’s team of consultants manage the communication and remediation activity which include Client Outreach, renegotiation of  bilateral contracts and producing weekly KPI’s on the performance of the project for the related project managers and teams.

 

 

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