New York Dividend Equivalent Shares

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US-CC-18-355F
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FAQ

The branch profits tax is imposed on the dividend equivalent amount (DEA), which are the after-tax effectively connected earnings and profits (ECEP) that are not reinvested in the United States and are deemed to have been effectively distributed out of the U.S. branch.

A dividend equivalent right entitles the recipient to receive credits equal to the cash or stock dividends or other distributions that would have been received on shares of stock had the shares been issued and outstanding on the dividend record date.

Engaging in business in the US or holding assets that generate ECI create an additional layer of taxation known as the 'Branch Profits Tax' (BPT), which is essentially a tax on deemed dividends and is typically assessed at 30%; if the foreign corporation qualifies for treaty benefits, this rate can be lowered.

The dividend equivalent amount is the amount of the foreign corporation's effectively connected earnings and profits for the tax year with certain adjustments for changes in the value of the equity of the foreign corporation's U.S. trade or business.

Dividend Equivalent means a right, granted to an Eligible Person to receive cash, Stock, other Awards or other property equal in value to dividends paid with respect to a specified number of shares of Stock, or other periodic payments.

A dividend equivalent payment is treated as a dividend from sources within the United States. ingly, the dividend is subject to a flat 30-percent withholding tax, or lower tax rate provided by a treaty if received by a nonresident alien individual or a foreign corporation.

A dividend equivalent payment is treated as a dividend from sources within the United States. ingly, the dividend is subject to a flat 30-percent withholding tax, or lower tax rate provided by a treaty if received by a nonresident alien individual or a foreign corporation.

A dividend equivalent right entitles the recipient to receive credits equal to the cash or stock dividends or other distributions that would have been received on shares of stock had the shares been issued and outstanding on the dividend record date.

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New York Dividend Equivalent Shares