Foreign Markets

Publication of OTC transactions carried out by S.S.I.F. Blue Rock Financial Services S.A. is carried out through the Bulgarian Stock Exchange as an “Approved publication arrangement” registered in the ESMA register on 25.10.2018. To view the reports, access the link: Bulgarian Stock Exchange

Witholding on Publicaly Traded Partnerships under IRS Sec. 1446(f)

As a result of recent U.S. legislation under Internal Revenue Code Section 1446(f), gross proceeds from sales of and certain distributions from Publicly Traded Partnerships (“PTPs”) will be subject to 10% withholding starting on January 1, 2023. Please note the following:

• Withholding applies to PTPs held by non-U.S. tax residents (both individuals and entities).
• Exemption from withholding may apply if a PTP releases a public statement called a “Qualified Notice” to indicate that the PTP meets the requirements of IRC Sec. 1446(f)-4(b)(3) to be exempt from withholding.
• Options and other derivative transactions with a PTP as the underlying security are not subject to withholding. However, if the option or derivative is converted into a PTP interest, a subsequent sale of such PTP interest will be subject to withholding.
• Withholding will be reported on the year-end Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding.

Additional information about IRC Sec. 1446(f) is available on the IRS website: http://www.irs.gov/individuals/international-taxpayers/partnership-withholding

This list identifies PTP securities which will be subject to withholding under IRC Sec. 1446(f) unless a “Qualified Notice” exemption is applicable at the time of the sale. For example, if a PTP publishes a Qualified Notice before December 31, 2022, then the PTP will be exempt from withholding in early 2023 once IRC Sec. 1446(f) takes effect. However, the PTP will be required to periodically reissue Qualified Notices as the validity period of each Qualified Notice is only 92 days from its posting. Clients should refer to the PTP’s website for information relating to Qualified Notices as this list identifies all PTPs irrespective of whether they have issued a Qualified Notice. Please note that this list of PTPs will be updated on a best efforts basis and is subject to change without notice.

PTP 10% List