ICMSA Publication


ICMSA Bulletin 180305/42: Guidelines for securities subject to US Tax Section 871(m)

This bulletin has been produced by the ICMSA Global Tax Sub-Committee to provide guidance relating to the 871(m) regulation.

The U.S. Internal Revenue Service (IRS) issued Final and Temporary Regulations on Dividend Equivalent Payments from U.S. sources on 19 January 2017. The purpose of the document is to provide guidance for:

  • The acceptance of section 871(m) securities issued and held through the ICSDs.
  • The reporting of section 871(m) DEPs (dividend equivalent payments) for the Form 1042-S reporting.
  • The reporting of inventory of unsold positions deemed non-reportable by the issuer for the purposes of Form 1042-S reporting.
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