The article focuses on the adoption of the Hiring Incentives to Restore Employment (Hire) Act by the U.S. Congress in 2010 which implemented withholding tax on dividend equivalents in particular cross-border equity swaps paid by Americans to foreign counterparts. Topics discussed include proposal from the U.S. Internal Revenue Service (IRS) to expand the withholding tax rules, equity-linked instruments (ELIs), and stocks of U.S. corporations
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