Finanse publiczne · 28.12.2010

Source of Income From Qualified Fails Charges; Correction

This document contains a correction to temporary regulations (TD 9508) thatwere published in the Federal Register on Wednesday, December 8, 2010 (75 FR 76262)providing guidance about the treatment of fails charges for purposes of sections 871 and 881, which generally require gross-basis taxation of foreign persons not otherwise subject to U.S. net-basis taxation and the withholding of such tax under sections 1441 and 1442.