On September 21, the Treasury Department and the IRS issued Notice 2026-61, further delaying the full implementation of the withholding rules on dividend equivalent payments. The Notice extends the phase-in of regulations under Section 871(m) of the Code and related provisions until 2029.

We examine the guidance in the Notice and its implications in this…

The US Senate Finance Committee has released a substitute (the “Senate version”) for the tax provisions of the “One Big Beautiful Bill,” the budget reconciliation bill currently under consideration by Congress. An earlier version of this bill was passed by the US House of Representatives on May 22, 2025 (the “House version”). Our prior Legal…