The Brazilian Senate is currently considering amendments to Law 9,249/1995 that would impose a withholding tax on dividends paid by a Brazilian resident to a nonresident beneficial owner. Under Law 9,249/1995 an exemption has applied since 1996. The amendments would adjust the wording of the law so that dividend payments made by a Brazilian company to Brazilian resident beneficial owners would remain exempt, but dividend payments to a nonresident beneficial owner would only be exempt if the shareholder's jurisdiction of residence provides reciprocal treatment for dividends paid to Brazil. If a jurisdiction does tax dividends paid to Brazilian beneficial owners,...