On 24 January 2017, U.S. IRS final and temporary regulations (TD 9815) were published in the Federal Register. TD 9815 provides guidance to 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, as well as certain other parties to section 871(m) transactions and their agents. TD 9815 adopts previously proposed regulations, and makes technical amendments to prior final and temporary regulations...