By David H Salzman
IN RECENT YEARS, non-US banks raising tier 1 capital have regularly turned to the US capital markets. The instruments used, commonly known as yankee tier 1 issues, might become even more attractive with the introduction of new US tax rules.
Following the signing into law of the Jobs and Growth Tax Relief Reconciliation Act earlier this year, US individuals who receive “qualified dividend income” will be taxed on it at a maximum rate of 15%.
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