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Dividend Tax Abuse: How Offshore Entities Dodge Taxes On U.S. Stock Dividends

Permanent Subcommittee on Investigations

Location: Room 106, Dirksen Senate Office Building

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Agenda

The Permanent Subcommittee on Investigations hearing, "Dividend Tax Abuse: How Offshore Entities Dodge Taxes On U.S. Stock Dividends," examined how some financial institutions have designed, marketed, and implemented transactions to enable foreign taxpayers, including offshore hedge funds, to dodge millions of dollars of taxes on U.S. stock dividends. The hearing also examined whether current law relating to dividend taxation and withholding should be strengthened. The Subcommittee issued a Subcommittee staff report in conjunction with the hearing summarizing its investigative findings and recommendations. Witnesses included representatives of U.S. financial institutions, offshore hedge funds, a tax expert, and the Internal Revenue Service.

Exhibits 1 - 34

In conjunction with this hearing, the Subcommittee Staff issued a report entitled, "Dividend Tax Abuse: How Offshore Entities Dodge Taxes on U.S. Stock Dividends."  The Report is available via the link located at the top left corner of this webpage. 

Witnesses

Panel 1

  • REUVEN S. AVI-YONAH
    Irwin I. Cohn Professor of Law
    University of Michigan School of Law
    Ann Arbor, Michigan
    Download Testimony (55k)

Panel 2

Panel 3

  • JOHN DEROSA
    Managing Director, Global Tax Director
    Lehman Brothers Inc.
    New York, New York
    Download Testimony (313k)
  • MATTHEW BERKE
    Managing Director and Global Head of Equity Risk Management
    Morgan Stanley & Co.
    New York, New York
    Download Testimony (35k)
  • ANDREA LEUNG
    Global Head of Synthetic Equity Finance
    Deutsche Bank AG
    New York, New York

Panel 4