Letters

Manufactured Overseas Dividends

Summary

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.

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