The US Treasury Department and the Internal Revenue Service (IRS) have issued temporary regulations (TD 9572) with guidance on payments of dividend equivalents for purposes of determining the source and character of such payments under section 871(m) of the Internal Revenue Code (IRC). The temporary regulations further extend the statutory definition of a specified notional principal contract (specified NPC) through 31 December 2013. Section 871(m) was enacted to address the treatment of substitute dividend payments made to foreign persons under securities lending transactions, sale-repurchase agreements, and certain NPCs, with effect for payments made after 14 September 2010. In general, a...