JPMorgan Chase Notes May Face 30% Withholding Tax for Non-US Holders
JPMorgan Chase & Co., also known as Guarantor, is issuing notes that may be subject to certain tax implications for non-US holders. According to a recent notice from the Internal Revenue Service (IRS), instruments issued prior to January 1, 2027, with no delta of one with respect to underlying securities that could pay US-source dividends, are excluded from the scope of Section 871(m) of the Code.
The notes in question have an estimated value derived by reference to an internal funding rate. This rate may differ from the market-implied funding rate for vanilla fixed income instruments issued by JPMorgan Chase & Co. or its affiliates. The use of an internal funding rate and any potential changes to that rate may have an adverse effect on the terms of the notes.
JPMorgan Chase & Co. is not required to pay additional amounts with respect to amounts withheld from Contingent Interest Payments paid to non-US holders. Non-US holders must comply with certification requirements to establish their eligibility for a reduction in or exemption from the 30% withholding tax under an applicable income tax treaty.