New US Withholding and Disclosure Provisions: This Isn’t Kansas Anymore

The United States has adopted new withholding and disclosure provisions that may add or increase a US tax burden to transactions. The changes in US withholding fall into three broad categories that are discussed in this article: (1) imposition of 30% withholding on payments to non-US persons that do not comply with US disclosure requirements, (2) elimination of the US domestic exceptions for non-US targeted bearer obligations and (3) the imposition of withholding on dividend equivalent amounts.