RE: Tender offer7 Jun 2024 15:15
JSB
US Witholding Tax is normally charged on income such as dividends , interest, et al paid by US companies to investors and can be reclaimed if there is a Double Taxation Treaty between the US and the recipients country and where double tax has been levied
Share buybacks via Tender are not treated as income in most countries and only the capital gain , where applicable, is subject to tax.
This 15% US Tax cannot be reclaimed imho as the Tender payment will not be taxed in the UK as income so no double tax reclaim possible.
So you could be hit with the 15% Witholding Tax plus a UK Capital Gains Tax bill .
Not funny