Qualifying for Tax Exemptions Under TEFRA D
In response to the issuance of Regulation S by the Securities & Exchange Commission (SEC), the US Treasury Department has issued amendments to US federal income tax regulations governing the procedures for qualifying interest paid on those obligations for the portfolio interest exemption from th...
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| Published in: | International financial law review p. 22 |
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| Main Authors: | , |
| Format: | Magazine Article |
| Language: | English |
| Published: |
London
Euromoney Institutional Investor PLC
01-09-1990
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| Subjects: | |
| Online Access: | Get full text |
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| Summary: | In response to the issuance of Regulation S by the Securities & Exchange Commission (SEC), the US Treasury Department has issued amendments to US federal income tax regulations governing the procedures for qualifying interest paid on those obligations for the portfolio interest exemption from the 30% US withholding tax. These regulations, referred to as the TEFRA D regulations, generally are effective for obligations issued after September 7, 1990. The new regulations contain 3 sets of requirements that must be met if the interest paid on a bearer obligation is to qualify as portfolio interest and avoid issuer sanctions. These are: 1. restrictions on offers and sales, 2. restrictions on delivery, and 3. certification. The regulations define a "distribution" and set a restricted period during which neither the issuer nor a distributor may offer or sell the obligation to a person who is within the US or its possessions or to a US person as defined in the Internal Revenue Code of 1986. |
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| ISSN: | 0262-6969 |