IRS Updates List of Tax Treaties Satisfying Requirements of IRC Section 1(h)(11)(C)(i)(II)

[35568]

January 03, 2024

TO: Tax Committee SUBJECTS: International/Global
Tax RE: IRS Updates List of Tax Treaties Satisfying Requirements of IRC Section 1(h)(11)(C)(i)(II)

 

The IRS issued Notice 2024-11, updating the list of US tax treaties (Notice 2011-64) that meet the requirements of section 1(h)(11)(C)(i)(II) for obtaining reduced capital gains rates on some dividend payments.

The guidance adds the treaty with Chile to the list. The list no longer includes the treaties with Russia and Hungary because both have ceased to meet the statutory requirements after the publication of Notice 2011-64. The guidance is effective for dividends paid after December 18, 2023, for Chile; after January 1, 2023, for Russia; and after January 8, 2023, for Hungary.

 

Katie Sunderland
Associate General Counsel