871 (m)的公告

存’s 871(m) Tax Event Announcements provide information-only announcements on dividend equivalent amounts under Internal Revenue Code 871(m).

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  The 871(m) Tax Event Announcement helps firms meet their obligations for tax withholding 和 reporting under 871(m) of the Internal Revenue Code by providing timely notification of dividend equivalent amounts.

  Section 871(m) imposes a 30 percent withholding tax on dividend equivalent payments that are made or deemed to be made to non-U.S. persons with respect to certain derivatives that reference equity (“Equity Derivatives”) of a U.S. 发行人. Under the Section 871(m) Regulations, an Equity Derivative held by a non-U.S. person can potentially give rise to a dividend equivalent subject to withholding tax. A complex set of rules must be followed in order for the withholding agent to determine if the withholding tax in fact applies, 和, 如果是这样的话, the amount of the dividend equivalent subject to withholding tax.

  The 871(m) Announcement simplifies compliance with these rules by sourcing dividend equivalent amounts directly from 发行人s 和 providing the information in the same manner as other corporate action information which allows these events to flow seamlessly into client’s tax processing engines.

• 谁可以使用该服务

  All 直接转矩 participants can use the service.

• 好处

  Sourcing the dividend equivalent amounts (“DEAs”) directly from 发行人s eliminates the need for firms to calculate DEAs, 和 holders of 871(m) transactions are treated consistently. 其他福利包括:

  
  

  • Announcement provides relevant data (i.e. timing 和 amount of dividend equivalent) in fielded format
  • Data flows in same manner as 存’s announcements on corporate actions
  • Position capture for balancing position to 存 records
  • Provides the underlying payable date for firms performing cashless withholding
  • Transparency into the underlying dividend that triggered the DEA
  • Systemic notifications through ISO 20022 messaging technology

  
  

• Information for Underwriters 和 Issuers of 871M Instruments

  When securities are made eligible at 存 depository, the issuing firm is required to attest to whether the security is a section 871(m) transaction by completing a 871(m)证明表格.

  For securities that 发行人s have attested are section 871(m) transactions, 发行人s are required to provide 存 with related information that triggered the dividend equivalent amounts as they occur, 通过完成 871(m) Dividend Equivalent Template.

  在收到dea后, 871(m) announcements are created, sent via ISO messages 和 made available for viewing in the CA Web.

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  公司行为处理:

  The Depository Trust Company (直接转矩) offers a wide array of services for processing corporate action events. These services include providing participants with information about their entitlements, 除了收集, 分配, 和 reporting payments across various corporate action event types, 包括分布, 赎回, 和重组.

  新股发行资格:

  The 新股发行资格 program allows newly issued securities as well as secondary offerings that meet 直接转矩’s eligibility criteria to become eligible for the depository 和 book-entry services of The Depository Trust Company (直接转矩).

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