US Treasury adds Chile to the list of treaty countries that meet the requirements of IRC Section 1(h)(11), removes Russia and Hungary

In Notice 2024-11 (Notice), issued 28 December 2023, the United States (US) Treasury Department (Treasury) and the Internal Revenue Service (IRS) updated the list of treaty partner countries that are relevant in determining whether a corporation is a "qualified foreign corporation" for purposes of applying IRC Section 1(h)(11). Under IRC Section 1(h)(11), reduced tax rates may apply to a dividend paid to an individual shareholder from a domestic corporation or a qualified foreign corporation.

Sin…