Manufactured Overseas Dividends
Published on:
October 16, 2006
The Securities Industry Association (SIA)* provides comments to the Internal Revenue Service (IRS) regarding the Chief Counsel Advisory on Manufactured Overseas Dividends (CCA). The CCA addresses the use of a special offset mechanism under which a U.K. subsidiary of a U.S. financial services company utilized foreign dividend withholding tax in certain circumstances. SIA shares its profession expertise and practical experience relating to the CCA with the IRS.
*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.