Читать книгу International Taxation - Adnan Islam - Страница 85

U.S. source dividends also include all dividend equivalent payments. Dividend equivalent payments include substitute dividends, payments made pursuant to a specified notional principal contract, and all similar payments that, directly or indirectly, are contingent on or determined by reference to, the payment of a dividend from U.S. sources. The IRS has issued final regulations on this topic.