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IRS GuideWire December 28, 2023

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Issue Number:    Notice 2024-11

Inside This Issue


Notice 2024-11 updates the list of treaties that meet the requirements of section 1(h)(11) (qualified dividends).

Under section 1(h)(11), a dividend paid to an individual shareholder from either a domestic corporation or a "qualified foreign corporation" generally is subject to tax at the reduced rates applicable to certain capital gains. A qualified foreign corporation includes certain foreign corporations that are eligible for benefits of a comprehensive income tax treaty with the United States that the Secretary determines is satisfactory for purposes of this provision and that includes an exchange of information program.

Notice 2024-11 will be in IRB: 2024-2, dated January 08, 2024.

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