Form-67 query - Urgent

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Sanjeev (Querist)
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08 January 2021 Dear Sir,

I need to fill form-67 to avail FTC. Please help me with the response to these queries:
I hold ESPP shares of two foreign companies. These were given to me by my ex-employers.
One of the ex-employer was a US based company having India Office where I worked. Other ex-employer was a non-US based company, having an India office where I worked. But this second employer had shares listed in NASDAQ.
Both companies gave dividend. I need to avail the FTC credit for the tax withheld by the US Broker for both the companies.
1. For the FTC purpose, is the country of origin (to be mentioned in Form-67) for dividend income from the second company (non-US company but listed at NASDAQ) to be mentioned as US in Form-67 or something else ? Please note that the tax is withheld by the US broker listed at NASDAQ

2. For one company, the US broker withheld the tax on dividend at the rate of 25% (US company), whereas for the other (non-US company) it withheld the tax on dividend at the rate of 15%. Does this mean that I need to have two separate rows in form-16, for the same country (US), one for 25% deduction and other for 15% deduction ? Form-67 asks for rate of tax deduction as per DTAA. How can one country have two rates of deduction (25 and 15%) in two separate rows.

Please help.

CA R SEETHARAMAN

CA R SEETHARAMAN (Expert)
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09 January 2021 1 As dividend paid from US mention country of origin as US.
2 Fill two rates and amount in form 67. Accept what ever TDS form given to you. Total amount should match.

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