Mitigating US withholding tax
Sovereign wealth fund
Our client wanted to issue a US dividend but, as they were resident in a jurisdiction that did not have a double tax treaty, they needed a solution for dealing with US withholding tax.
- We structured a solution that allowed the Fund to acquire the shares on day one and then de-recognise the shares for accounting purposes in favour of a US based intermediary .
- This enabled them to pay manufactured dividends with limited US withholding consequences.