存托信托 & 清算 Corporation’s (存) 21st annual Global Tax Forum – held virtually this year over two morning sessions, April 21 and April 22 – featured several in-depth discussions around the implications of the new U.S. 证券交易委员会.1446 (f)规定, which relates to the withholding obligations for certain dispositions by foreign partners of interests in partnerships engaged in a U.S. 贸易或商业.
Other topics covered in the forum included 存’s myriad solutions to help participants comply with these new regulations and the capabilities of 存托信托 Company’s (直接转矩) 结算 system.
存全球税务论坛, 自1998年起每年举行一次, was cancelled last year in the uncertainty of the COVID-19 pandemic. Hosting virtually this year, 然而, meant that over 250 clients from around the globe were able to log in and participate in the two days of presentations.
第一天:第1446(f)条
The first presentation of the forum featured Tara Ferris, Principal, Ernst & 年轻的律师事务所. Ferris provided a deeper dive into 1446(f), a new tax code that requires brokers to withhold on amounts realized from sales of publicly traded partnerships by non-U.S. 人. 她的演讲, Ferris summarized the Publicly Traded 合作伙伴hips (PTP) requirements and provided several examples of Qualified Notices.
The next session of the first day was a 存 panel with Ian DeSacia, 导演, 全球税务服务, 和Steven Tang, vnsr威尼斯城官网登入经理, 全球税务服务, discussing 存’s solutions to help participants comply with these new regulations, including Corporate Action Announcements disseminating information from Qualified Notices to help Participants comply with withholding on distributions, and also notifying them of exceptions to withholding on dispositions.
DeSacia, Tang and Ferris collectively fielded a variety of submitted questions from the forum participants, 和埃利斯·利维, 存董事总经理, 税务顾问 & 公司税主管, concluded the first day with a reminder to everyone that these are very complex regulations and clients should reach out their relationship managers for questions on 存 solutions and with their own tax advisors about 1446(f).
Day 2: 结算 and Tax
The second day of the forum started with a panel discussion between Jay Klein, U.S. 税收主要, 普华永道, 和约翰·阿贝尔, 存 Executive 导演 of Clearance and 结算 Product Management, 列维主持. The panel discussed various ways in which trades settle via 存’s clearing subsidiaries, 直接转矩 and National 证券交易委员会urities 清算 Corporation (NSCC) and included examples of when 1446(f) withholding would apply, and which party would be responsible for enacting such withholding.
The final presentation returned to DeSacia, who discussed the planned roll out of 直接转矩’s repository of Participant tax forms. The repository will provide Participants with one-stop shopping that will house member tax forms, instead of Participants requesting tax forms from each of their counterparties within 直接转矩. The Regs allow 直接转矩’s Participants to rely on tax forms provided by 直接转矩 for withholding and reporting tax under 1446(f). 另外, Participants that do not want to have their tax form in the repository will have the ability to opt out.
DeSacia, Klein, Abel and Levy fielded questions for several minutes at the end of day 2. Levy reminded forum participants that the PowerPoint decks were available, and that recordings of the sessions would be made available, 太.