CFR 26-1.1441-6T-2014
Internal Revenue. Part1:Income taxes(continued). Section1.1441-6T:Claim of reduced withholding under an income tax treaty(temporary).

Standard No.
CFR 26-1.1441-6T-2014
Release Date
2014
Published By
US-CFR-file
Latest
CFR 26-1.1441-6T-2014
Scope
(a) Withholding agent defined—(1) In general. For purposes of chapter 3 of the Internal Revenue Code and the reg-ulations under such chapter, the term withholding agent means any person, U.S. or foreign, that has the control, receipt, custody, disposal, or payment of an item of income of a foreign per-son subject to withholding, including (but not limited to) a foreign inter-mediary described in § 1.1441–1(e)(3)(i), a foreign partnership, or a U.S. branch described in § 1.1441–1(b)(2)(iv)(A) or (E). See §§ 1.1441–1(b)(2) and (3) and 1.1441– 5(c), (d), and (e), for rules to determine whether a payment is considered made to a foreign person. Any person who meets the definition of a withholding agent is required to deposit any tax withheld under § 1.1461–1(a) and to make the returns prescribed by § 1.1461– 1(b) and (c), except as otherwise may be required by a qualified intermediary withholding agreement, a withholding foreign partnership agreement, or a withholding foreign trust agreement. When several persons qualify as with-holding agents with respect to a single payment, only one tax is required to be withheld and deposited. See § 1.1461–1. A person who, as a nominee described in § 1.6031(c)–1T, has furnished to a part-nership all of the information required to be furnished under § 1.6031(c)–1T(a) shall not be treated as a withholding agent if it has notified the partnership that it is treating the provision of in-formation to the partnership as a dis-charge of its obligations as a with-holding agent.

CFR 26-1.1441-6T-2014 history

  • 2014 CFR 26-1.1441-6T-2014 Internal Revenue. Part1:Income taxes(continued). Section1.1441-6T:Claim of reduced withholding under an income tax treaty(temporary).



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