• Treasury Issues New Final and Proposed Regulations on Dividend Equivalent Transactions
  • December 17, 2013
  • Law Firm: Alston Bird LLP - Atlanta Office
  • On December 4, 2013, the U.S. Treasury issued final and proposed regulations under Section 871(m) of the Code. The final rules extend the current definition of “notional principal contracts” (NPCs) to payments made before January 1, 2016, while the proposed regulations introduce rules that may modify the scope and application of Section 871(m)’s resourcing rule for “dividend equivalent” payments. In general, these new regulations are a positive development in this complex area, offering the financial services sector and affected investors some present certainty and additional time to digest the new proposals.