Datasheet 搜索 > 热敏电阻 > VISHAY（威世） > NTCS0603E3202JLT 数据手册 > NTCS0603E3202JLT 其他数据使用手册 3/9 页
器件3D模型￥ 1.157
NTCS0603E3202JLT 其他数据使用手册 - VISHAY（威世）
制造商:
VISHAY（威世）
分类:
热敏电阻
封装:
0603
描述:
温度传感器
Pictures:
3D模型
符号图
焊盘图
引脚图
产品图
NTCS0603E3202JLT数据手册
Page:
of 9 Go
若手册格式错乱，请下载阅览PDF原文件
3204
Federal Register / Vol. 77, No. 14 / Monday, January 23, 2012 / Proposed Rules
posted as collateral on any day that the
NPC is in effect.
The proposed regulations treat an
NPC as a specified NPC if the term of
the contract has fewer than 90 days. As
the market for equity-linked NPCs grew
and evolved, taxpayers began to
purchase and sell NPCs in lieu of
trading the underlying equities. Many
transactions entered into to avoid U.S.
withholding tax on dividends involved
short-term equity swaps around an ex-
dividend date. In many cases, the
taxpayer entered into an NPC with a
financial institution that acquired the
underlying security as a hedge of a
contract; the parties then settled or
terminated that contract within days or
weeks of the date it was entered into.
When an NPC has a short duration and
is in effect over an ex-dividend date, the
source rule of section 871(m) should
take precedence over the general source
rule for NPC income in § 1.863–7.
In some situations, the long party
controls the acquisition of stock that the
short party uses to hedge its position
under the contract or has directed the
short party to sell the short party’s
hedge to a particular purchaser at a
specific price and date. The long party
in these situations may exercise such
control over the short party’s hedge
pursuant to terms of a written agreement
or through course of conduct. The
Treasury Department and the IRS
believe that the source rule of section
871(m) should apply to an NPC when a
long party exercises control over the
short party’s hedge. Accordingly, the
proposed regulations treat an NPC as a
specified NPC when a foreign investor
controls the short party’s hedge or
participates in an underlying equity
control program. An underlying equity
control program is any system, whether
carried out electronically or otherwise,
that allows a long party to direct its
counterparty’s hedge of an NPC or that
allows a long party to acquire economic
exposure to an underlying security and
to determine the form of the transaction
later. An underlying equity control
program, however, does not include an
electronic trading platform that allows a
customer to place an order to enter into
an NPC with a dealer, provided that the
dealer independently determines
whether and how to hedge its position
without customer direction.
The proposed regulations treat an
equity swap as a specified NPC when
the notional principal amount of an
NPC is a significant percentage of the
trading volume. Specifically, when the
notional principal amount of the NPC is
greater than five percent of the total
public float or 20 percent of the 30-day
average daily trading volume such
contract is treated as a specified NPC. If
a long party has multiple NPCs that
reference the same underlying security,
the notional principal amounts of those
contracts must be aggregated when
determining whether the notional
principal amount represents a
significant percentage of the trading
volume.
A special dividend is a nonrecurring
payment to shareholders that is in
addition to any recurring dividend
payment. The proposed regulations
provide that any NPC is a specified NPC
when the parties enter into the NPC
after the announcement of a special
dividend on the underlying stock. The
Treasury Department and the IRS
believe that an NPC entered into after
the announcement of a special dividend
and before the ex-dividend date is more
likely to be entered into for the purpose
of avoiding U.S. tax than an NPC
referencing a stock that pays only a
recurring dividend.
To prevent taxpayers from avoiding
these rules through related parties, the
proposed regulations provide that each
related person (within the meaning of
section 267(b) or 707(b)(1)) is treated as
a party to the contract. The proposed
regulations also provide that an NPC
entered into between two related dealers
is not a specified NPC if the NPC hedges
risk associated with another NPC
entered into with a third party. This rule
is intended to avoid excessive
withholding tax on transactions
commonly employed by dealers to
transfer risk from one entity to another
within their affiliated group.
Notwithstanding these rules defining
the term specified NPC, the
Commissioner may challenge
transactions that are designed to avoid
the application of these rules under
applicable judicial doctrines. Nothing in
these rules precludes the Commissioner
from asserting that a contract labeled as
an NPC or other equity derivative is in
fact an ownership interest in the equity
referenced in the contract.
3. Underlying Security
The term underlying security means
any security that pays a U.S. source
dividend. If an NPC references more
than one security, each reference
security is treated as an underlying
security of a separate NPC. If an NPC
references a customized index, each
component security of that index is
treated as an underlying security in a
separate NPC for purposes of this
section. An index is treated as a
customized index if it is (1) a narrow-
based index or (2) any other index
unless futures contracts or options
contracts referencing the index trade on
a qualified board or exchange. The
definition of the ‘‘narrow-based index’’
is generally based on the definition of
that term in the Securities Exchange Act
of 1934, Section 3(a)(55)(B).
4. Specified NPC Status Arising During
Term of Contract; Liability of
Withholding Agent; and Other
Conforming Amendments
These proposed regulations amend
several regulations under section 1441
to require a withholding agent to
withhold tax owed with respect to a
dividend equivalent. If an NPC that is
not a specified NPC on the date it is
entered into becomes a specified NPC
during the term of the contract, it will
be treated as though it had been a
specified NPC during the entire term of
the contract. Payments made under the
NPC by reference to the payment of a
dividend from sources within the
United States will be re-characterized as
dividend equivalents and all tax owed
with respect to such dividend
equivalents will be due at the time of
the next payment made under the NPC,
including a termination payment. In
cases where the tax owed is greater than
the next payment made under the
specified NPC, the withholding agent is
responsible for reporting and depositing
the total amount due with the IRS. The
mechanism by which a withholding
agent collects the amount due from the
taxpayer is left to the discretion of the
withholding agent and the taxpayer, and
is not specified in these proposed
regulations. The withholding agent must
deposit the total amount due even if it
cannot collect the amount from the
counterparty.
The proposed regulations provide that
dividend equivalents are treated as
income from investments in stock for
purposes of section 892; taxpayers may
rely on § 1.892–3(a)(6) until final
regulations are issued. Finally, the
proposed regulations provide that a
reduced rate of withholding tax
provided by an income tax convention
for dividends paid or derived by a
foreign person applies to a dividend
equivalent.
Special Analyses
It has been determined that this notice
of proposed rulemaking is not a
significant regulatory action as defined
in Executive Order 12866. Therefore, a
regulatory assessment is not required. It
also has been determined that section
553(b) of the Administrative Procedure
Act (5 U.S.C. chapter 5) does not apply
to these regulations. Because the
regulation does not impose a collection
of information on small entities, the
Regulatory Flexibility Act (5 U.S.C.
VerDate Mar<15>2010 16:33 Jan 20, 2012 Jkt 226001 PO 00000 Frm 00046 Fmt 4702 Sfmt 4702 E:\FR\FM\23JAP1.SGM 23JAP1
srobinson on DSK4SPTVN1PROD with PROPOSALS
器件 Datasheet 文档搜索
AiEMA 数据库涵盖高达 72,405,303 个元件的数据手册，每天更新 5,000 多个 PDF 文件
