On 17 September 2015, the U.S. Department of Treasury and IRS issued final and temporary regulations (T.D. 9734) on dividend equivalents from sources within the U.S. The regulations provide guidance for nonresident alien individuals and foreign corporations that hold certain financial products providing for payments that are contingent upon or determined by reference to U.S. source dividend payments. The regulations also provide guidance to withholding agents that are responsible for withholding U.S. tax with respect to a dividend equivalent. In particular, the final regulations cover: The dividend equivalent definition, which includes: Any substitute dividend that references a U.S. source dividend...