This chapter will explain the trading, safe custody and payment chain in financial institutions together with an explanation of the various operating models that can be used. Particular attention will be given to new Sect. 144(a) and 1446(f) withholding regulations on the taxation of realised gains on disposal of interests in publicly traded partnershipsPublicly traded partnerships (PTP)—which is a new area of the 2023 QIQualified Intermediary (QI) Agreement.

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Withholding

  • Ross K. McGill,
  • Kirsty V. Pitkin

摘要

This chapter will explain the trading, safe custody and payment chain in financial institutions together with an explanation of the various operating models that can be used. Particular attention will be given to new Sect. 144(a) and 1446(f) withholding regulations on the taxation of realised gains on disposal of interests in publicly traded partnershipsPublicly traded partnerships (PTP)—which is a new area of the 2023 QIQualified Intermediary (QI) Agreement.