INCOME TAX

Notice 2010–46, page 757. This notice addresses the U.S. tax imposed on substitute dividend payments received by foreign taxpayers that lend U.S. dividend paying securities in securities lending transactions. The notice announces the upcoming withdrawal of Notice 97–66, outlines a proposed regulatory framework to address potential over-withholding that may occur as a result of the HIRE Act, and provides transaction relief with respect to substitute dividend payments made between the effective date of the HIRE Act and the issuance of regulations. Notice 97–66 modified.