On January 19, 2016, the US Internal Revenue Service issued substantial revisions to the rules for withholding on dividend equivalents. On the very next day, the Trump administration issued a freeze on all regulations issued by the Obama administration that had not yet been published in the Federal Register. Thus, these latest revisions to the qualified derivative dealer and dividend equivalent withholding rules are in a state of suspended animation. This Legal Update, prepared by Mark Leeds of the New York office of Mayer Brown, analyzes these developments.

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