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Greenberg Traurig LLP | USA | 21 May 2010

When the other shoe falls: IRS Notice 2010-46 restricts the application of Notice 97-66 in advance of the effective date of Code 871(l)

Notice 97-661 created an opportunity for non-United States financial institutions to participate in the securities lending markets for stocks of U.S. corporations without suffering burdensome U.S. federal withholding taxes.

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