Office of Chief Counsel Internal Revenue Service Memorandum

withholding tax that would be applicable to U.S. source dividends paid by a U.S. person directly to the recipient of the substitute payment over the rate of U.S. withholding tax that would be applicable to U.S. source dividends paid by a U.S. person directly to the payor of the substitute payment. Notice 97-66 at § 3, 1997-2 C.B. 328 (1997). C. ................
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