The G5 Position Letter on Dividend Equivalent Payments

SIFMA provides comments to the Department of the Treasury and the Internal Revenue Service (IRS) in response to the letter sent to the US Treasury from the United Kingdom, Germany, Spain, France, and Italy (the G5 countries) stating their position that dividend equivalent payments, as defined by Code Section 871(m) and the underlying regulations, do not qualify as dividends under the applicable United States tax treaty when paid by non-US entities.