Webinar: Section 871(m) withholding tax regime

UK

AIMA invites members to participate in a webinar hosted by PwC on Wednesday 1st March 2017 at 4.00 pm (London) / 11.00 am (East Coast)) / 9.00 am (West Coast).

New final, temporary and proposed regulations issued on 19 January 2017 provide guidance on the existing Section 871(m) regulations and supplement other recent IRS guidance and the new form of qualified intermediary agreement. These regulations confirm that Section 871(m) will apply to delta-one transactions only for 2017, provide for changes to the treatment of payments made to qualified derivatives dealers and calculation of their tax liability, and address many comments outstanding with respect to the existing Section 871(m) regulations.

The new regulations were issued immediately prior to the memorandum issued by the White House Chief of Staff imposing a freeze on registration of new measures but nevertheless were published in the Federal Register on 24 January 2017 and, although their status is not completely clear, appear to be currently effective.

Hear from our panel as they provide an overview of the changes, analyse the implications for the alternative asset management industry and suggest practical steps that managers and other industry participants should be taking.