Bloomberg Tax
Feb. 24, 2023, 5:26 PM

Depositary Receipt Payments to Foreign Firms US-Sourced, IRS Says

Michael Rapoport
Michael Rapoport
Senior Reporter, Bloomberg Tax
Lauren Vella
Lauren Vella
Reporter

The payments that foreign companies receive from US banks under sponsored American Depositary Receipt programs should be considered US-source income and subject to withholding of US taxes, according to an IRS memo released Friday.

Sponsored ADR programs are jointly established by a foreign company and a US bank, with the bank often paying a portion of the company’s expenses or sharing revenue with the company in exchange for the exclusive right to handle the trading of its ADRs.

  • That exclusivity constitutes a property right under tax code Section 861, and the US is the location of the capital ...