The US Treasury Department and the Internal Revenue Service (IRS) have issued final regulations (TD 9648) under section 871(m) of the Internal Revenue Code (IRC) to provide guidance to non-resident individuals and foreign corporations that hold specified notional principal contracts ("specified NPCs") providing for payments that are contingent upon or determined by reference to US source dividend payments and to withholding agents. IRC section 871(m) treats a "dividend equivalent" as a dividend from sources within the United States for purposes of the US gross basis income tax and subjects such dividend equivalent, if paid to a non-resident person, to the...