Description of a potential Section 871(m) IRC transaction
A potential Section 871(m) IRC transaction refers to transactions that could be subject to Section 871(m) IRC of the United States Internal Revenue Code (IRC).
Such transaction may be any derivative transaction that references interest in at least one security that could give rise to a United States source dividend. If the transaction is in-scope and subject to Section 871(m) IRC, a withholding tax may be levied on the dividend equivalent amounts from derivatives that reference dividend paying United States equities.
