Notice 2011-64 updates the list of U.S. income tax treaties that meet the requirements of section 1(h)(11), which was last updated in Notice 2006-101, 2006-2 C.B. 930, to reflect two new income tax treaties that have entered into force since the publication of Notice 2006-101.

Pursuant to section 1(h)(11) of the Internal Revenue Code, a dividend paid to an individual shareholder from a domestic corporation or a “qualified foreign corporation” is taxed at the reduced rates applicable to certain capital gains. A qualified foreign corporation includes certain foreign corporations that are eligible for benefits of a comprehensive income tax treaty with the United States that the Secretary determines is satisfactory for purposes of section 1(h)(11).

Notice 2011-64 will appear in IRB 2011-37 dated Sept. 12, 2011.

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