Epstein File EFTA01378985: Holder and Treat (DS10)

Epstein Index›Documents›EFTA01378985

⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01378985: Holder and Treat (DS10)

General DocumentDate unavailableEFTA013789851 keyword hits

0

views

0

shares

0

reactions

1

persons

1

keywords

4

excerpts

A legal opinion from Davis Polk & Wardwell LLP addresses the tax treatment of securities under U.S. federal income tax law. The document discusses how dividend equivalent payments and coupons paid to non-U.S. holders of securities should be treated for withholding tax purposes, subject to applicable certification requirements.

👤 Named in This Document

Eric Holder

🔑 Evidence Keywords

treat

📋 Key Excerpts4

PersonKeyword

Excerpt 1

In the opinion of our counsel, Davis Polk & Wardwell LLP, it is reasonable under current law to **treat** the securities for U.S. federal income tax purposes

Excerpt 2

Holders Generally- Substitute Dividend and Dividend Equivalent Payments," we currently do not intend to **treat** coupons paid to a Non-U.S.

Excerpt 3

**Holder** (as defined in the accompanying product supplement) of the securities as subject to U.S. federal withholding tax, provided that the Non-U.S.