Which treaties qualify for the JGTRRA's special dividend rate?
Under Sec. 1(h)(11)(B)(i)(II) and (C), as added by JGTRRA Section 302(a), dividend from foreign securities qualify for the lower rate if they are traded on an established U.S. securities market. Foreign securities not traded on a U.S. securities market can qualify if certain treaty requirements are met. Notice 2003-69 lists the foreign countries whose tax treaties meet the JGTRRA's requirements. Exhibit 1 above lists the countries mentioned in the notice.
Exhibit 1: Countries with qualifying tax treaties
Trinidad and Tobago
FROM MICHAEL D. KOPPEL, CPA, MBA, MSA, GRAY, GRAY & GRAY, LLP, WESTWOOD, MA
Michael D. Koppel, CPA
Gray, Gray & Gray, LLP
Accounting Firms Associated, Inc. (AFAi)
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|Title Annotation:||Jobs and Growth Tax Relief Reconciliation Act of 2003|
|Author:||Koppel, Michael D.|
|Publication:||The Tax Adviser|
|Date:||Dec 1, 2003|
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