QDD definition

QDD means Qualified Derivatives Dealer of the Code Section 871(m) of the U.S. Internal Revenue Code of 1986, as amended and is further defined under Section 475(c) (1) of the Code. Qualified Derivatives Dealers pursuant to the new Qualified Intermediary regime addresses the issue of multiple withholding on the same stream of dividends.
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Examples of QDD in a sentence

  • For purposes of a QI acting as a QDD or any determination relating to section 871(m), “underlying security” has the meaning provided in §1.871-15(a)(15).

  • With respect to a QI acting as a QDD, “account” means any potential section 871(m) transaction or underlying security where QDD receives payments as a principal and any potential section 871(m) transaction where QDD makes payments as a principal.

  • QI, however, may not enter an agreement under this section 4.06 with any account holder for which it acts as a QDD.

  • A QDD must determine its QDD tax liability due under sections 3.09(A) and (B) on the date provided in §1.871-15(j)(2) for the applicable dividend.

  • If QI is acting as a QDD, it must assume primary chapters 3 and 4 withholding responsibility for any dividend equivalent payment that it makes and must withhold with respect to a dividend equivalent payment on the dividend payment date for the applicable dividend (as determined in §1.1441-2(e)(4)).

  • The maximum amount of a QDD is $100,000 per taxpayer; is not subject to the premature distribution penalty tax of 10% (or 25% in the case of a SIMPLE-IRA), and will be taxed pro rata over a 3 year period unless the taxpayer elects to pay all of the taxes in the year of the distribution.

  • While the section 871(m) amount computation was expanded to permit offsets for amounts that do not give rise to withholding tax payments under the 2017 QI Agreement, the QDD is liable for tax on any dividends received, without offset or credit forward to address concerns raised by the expansion of offsets in the section 871(m) amount computation.

  • This rule applies to QIs that are FFIs and are applying for QDD status on behalf of the home office or any branch.

  • A QDD must treat any dividend equivalent as a dividend from sources within the United States for purposes of section 881 and chapter 3 and chapter 4 consistent section 871(m) and the regulations thereunder.

  • A QDD must determine its QDD tax liability due under section 3.09(C) at the time the payments are treated as received under the Code and the regulations promulgated thereunder.

Related to QDD

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