As discussed in more detail in a prior column, the Hiring Incentives to Restore Employment Act (Hire Act), which was enacted in March of this year, treats as a US-source dividend any dividend equivalent for purposes of US withholding tax provisions. The effect of this provision, which applies to payments after September 14 2010, is to impose a 30% withholding tax on such payments unless reduced by treaty.
December 21 2010