Tax Pros Want Pared-Down Documenting Rule for Dividend Guidance

The IRS and Treasury Department should consider significantly modifying its requirement to record dividend payments to a US company by a foreign subsidiary in new guidance, a group of tax practitioners said.

The American Institute of Certified Public Accountants recommended the government “eliminate or significantly pare back” a requirement in Notice 2025-75 to document and determine where a dividend paid to a US shareholder increased their taxable income.

The group, in a letter to the agencies published Tuesday, argued that the requirement to document these transactions is “ambiguous and potentially onerous.”

In addition, obtaining tax information from sellers that aren’t ...