Milestone is a boutique international tax practice established in Mayfair, London.


Mitigating US withholding tax

The Client

Sovereign wealth fund

The Problem

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.

The Solution

  • 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.