Notice 2024-11: Updated list of treaties meeting qualified dividend requirements adds Chile, removes Hungary and Russia
List of treaties that meet the requirements of section 1(h)(11) with respect to “qualified dividends”
List of treaties that meet the requirements of section 1(h)(11)
The IRS today released Notice 2024-11 [PDF 124 KB] updating the list of treaties that meet the requirements of section 1(h)(11) with respect to “qualified dividends.”
Under section 1(h)(11), a dividend paid to an individual shareholder from either a domestic corporation or a "qualified foreign corporation" generally is subject to tax 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 this provision and that includes an exchange of information program.
Notice 2024-11 updates the list of treaties that meet those requirements to:
- Add the treaty with Chile, which entered into force on December 19, 2023—effective for dividends paid on or after December 19, 2023
- Remove the treaty with Hungary, which terminated on January 8, 2023—effective for dividends paid on or after January 8, 2023
- Remove the treaty with Russia, under which the exchange of information program has been paused—effective with for dividends paid on or after January 1, 2023
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