80 FR 75946 - Dividend Equivalents From Sources Within the United States; Correction

DEPARTMENT OF THE TREASURY
Internal Revenue Service

Federal Register Volume 80, Issue 234 (December 7, 2015)

This document contains corrections to final and temporary regulations (TD 9734) that was published in the Federal Register on September 18, 2015 (80 FR 56866). These corrections include a change to the effective date that was applicable to transactions issued on or after January 1, 2016, and before January 1, 2017. This document provides guidance to nonresident alien individuals and foreign corporations that hold certain financial products providing for payments that are contingent upon or determined by reference to U.S. source dividend payments.

[Federal Register Volume 80, Number 234 (Monday, December 7, 2015)]
[Rules and Regulations]
[Pages 75946-75947]
From the Federal Register Online  [www.thefederalregister.org]
[FR Doc No: 2015-30778]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9734]
RIN 1545-BJ56


Dividend Equivalents From Sources Within the United States; 
Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final and temporary regulations; correction.

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SUMMARY: This document contains corrections to final and temporary 
regulations (TD 9734) that was published in the Federal Register on 
September 18, 2015 (80 FR 56866). These corrections include a change to 
the effective date that was applicable to transactions issued on or 
after January 1,

[[Page 75947]]

2016, and before January 1, 2017. This document provides guidance to 
nonresident alien individuals and foreign corporations that hold 
certain financial products providing for payments that are contingent 
upon or determined by reference to U.S. source dividend payments.

DATES: This correction is effective on December 7, 2015 and applicable 
on September 18, 2015.

FOR FURTHER INFORMATION CONTACT: Peter Merkel or Karen Walny at (202) 
317-6938 (not a toll free number).

SUPPLEMENTARY INFORMATION: 

Background

    The final and temporary regulations (TD 9734) that are the subject 
of this correction are under sections 871 and 894 of the Internal 
Revenue Code.

Need for Correction

    As published, the final and temporary regulations (TD 9734) contain 
errors that may prove to be misleading and are in need of 
clarification.

Correction of Publication

    Accordingly, the final and temporary regulations (TD 9734), that 
are the subject of FR Doc. 2015-21759, are corrected as follows:
    1. On page 56866, in the preamble, the first column, under the 
caption ``DATES'', the fourth through seventh lines of the paragraph, 
the language ``applicability, see Sec. Sec.  1.871-14(j)(3), 1.871-
15(r), 1.871-15T(r)(4), 1.1441-1(f)(4), 1.1441-1T(f)(3), 1.1441-2(f), 
1.1441-3(h)(3), 1.1441-7(a)(4), and '' is corrected to read 
``applicability, see Sec. Sec.  1.871-14(j)(3), 1.871-15(r), 1.871-
15T(r)(4), 1.1441-1(f)(4), 1.1441-1T(f)(3), 1.1441-2(f), 1.1441-
3(h)(3), 1.1441-7(a)(4), 1.1461-1(c)(2)(iii), and''.
    2. On page 56866, in the preamble, the first column, the eleventh 
line from the bottom of the column, the language ``871(m). This 
information will be used'' is corrected to read ``871(m) of the 
Internal Revenue Code. This information will be used''.
    3. On page 56868, in the preamble, the first column, the ninth line 
from the bottom of the column, the language ``discussed in section E.1 
of this'' is corrected to read ``discussed in section F.1 of this''.
    4. On page 56869, in the preamble, the second column, the tenth 
line of the first full paragraph, the language ``dividends. As noted in 
Part II.L. of this'' is corrected to read ``dividends. As noted in Part 
II.M. of this''.
    5. On page 56870, in the preamble, the first column, the thirty-
second line from the bottom of the column, the language ``D. Payment of 
a Dividend Equivalent'' is corrected to read ``E. Payment of a Dividend 
Equivalent''.
    6. On page 56870, in the preamble, the second column, the twenty-
second line of the second full paragraph, the language ``equivalent, as 
discussed in Part II.M of'' is corrected to read ``equivalent, as 
discussed in Part II.N of''.
    7. On page 56870, in the preamble, the second column, the 
eighteenth line from the bottom of the column, the language ``E. Amount 
of a Dividend Equivalent'' is corrected to read ``F. Amount of a 
Dividend Equivalent''.
    8. On page 56870, in the preamble, the third column, the eleventh 
line from the bottom of the column, the language ``defined in Sec.  
1.871-15(a)(14)(ii)'' is corrected to read ``defined in Sec.  1.871-
15(a)(5)''.
    9. On page 56871, in the preamble, the first column, the twenty-
sixth line from the bottom of the column, the language ``F. Qualified 
Indices'' is corrected to read ``G. Qualified Indices''.
    10. On page 56872, in the preamble, the first column, the last line 
of the first full paragraph, the language ``qualified index rule. See 
Sec.  1.871-15(l)'' is corrected to read ``qualified index rule. See 
Sec.  1.871-15(l).''.
    11. On page 56872, in the preamble, the second column, the sixth 
line from the bottom of the column, the language ``G. Combined 
Transactions'' is corrected to read ``H. Combined Transactions''.
    12. On page 56873, in the preamble, the third column, the twelfth 
line from the top of the column, the language ``H. Derivatives 
Referenced to Partnership'' is corrected to read ``I. Derivatives 
Referenced to Partnership''.
    13. On page 56873, in the preamble, the third column, the fifth 
line from the bottom of the column, the language ``I. Anti-Abuse Rule'' 
is corrected to read ``J. Anti-Abuse Rule''.
    14. On page 56874, in the preamble, the first column, the twenty-
fourth line from the top of the column, the language ``J. Reporting 
Obligations'' is corrected to read ``K. Reporting Obligations''.
    15. On page 56874, in the preamble, the first column, the fifteenth 
line of the second full paragraph, the language ``871(m) transaction 
the broker or dealer'' is corrected to read ``871(m) transaction, the 
broker or dealer''.
    16. On page 56874, in the preamble, the third column, the first 
line of column, the language ``K. Recordkeeping Rules'' is corrected to 
read ``L. Recordkeeping Rules''.
    17. On page 56874, in the preamble, the third column, the thirty-
second line from the top of column, the language ``L. Contingent and 
Convertible Debt'' is corrected to read ``M. Contingent and Convertible 
Debt''.
    18. On page 56875, in the preamble, the second column, the third 
line from the top of the column, the language ``M. Amounts Subject to 
Withholding'' is corrected to read ``N. Amounts Subject to 
Withholding''.
    19. On page 56877, in the preamble, the second column, the fifth 
line from the bottom of the third full paragraph, the language ``on the 
same underlying securities.'' is corrected to read ``on the same 
underlying security.''.
    20. On page 56878, in the preamble, the second column, under the 
paragraph heading ``IV. Effective/Applicability Date'', the third 
sentence of the first full paragraph is removed.

Martin V. Franks,
Chief, Publications and Regulations Branch, Legal Processing Division, 
Associate Chief Counsel, (Procedure and Administration).
[FR Doc. 2015-30778 Filed 12-4-15; 8:45 am]
 BILLING CODE 4830-01-P