" ... primarily addresses the withholding of U.S. income tax under [sections] 1441-1443 of the Internal Revenue Code from certain payments to foreign persons related to their U.S.-source income (colloquially, "payments of U.S.-source income"). The discussion sets forth the documentation requirements imposed under [sections] 1441, 1443 and chapter 61 ([sections] 6041-6050W), the information reporting requirements under [sections] 1461 and chapter 61 and the applicable backup withholding procedures under [section] 3406. The portfolio also addresses the relationship of withholding under [sections] 1441, 1442, and 1443 with the requirements imposed by chapter 61 and the backup withholding rules under [section] 3406, an important aspect of which is the mandatory presumption rules for withholding and reporting on payments in the absence of reliable documentation as to the classification and status of the payee. Additionally, the portfolio provides a detailed discussion of the procedures applicable to intermediaries, both qualified and non-qualified. Special topics include a discussion of the application of [section] 1441 to specific types of income such as the various types of interest income and effectively connected income. Other special topics include the application of the regulations to specific types of entities such as U.S. branches of certain foreign corporations, partnerships, trusts and estates, foreign governments and international organizations, and tax-exempt organizations ..."
Formerly published in Washington, D.C., 2000-2007.
Bibliography, etc. Note
Includes bibliographical references.
Formatted Contents Note
Detailed analysis. Introduction Documentation requirements for foreign persons under chapter 61 and [section] 3406 Section 6049: returns of information as to interest paid and original issue discount includible in gross income Section 6041 Sections 6041A, 6042, 6044 and 6045 Section 6050H: mortgage interest received in trade or business from individuals Section 6050I: information reporting relating to cash received in a trade or business Section 6050J: information returns relating to foreclosures and abandonments of security Section 6050M: returns relating to contracts with federal executive agencies Section 6050P: information reporting with respect to cancellation of indebtedness income Section 6050N: royalties paid after December 31, 1986 Section 6050S: information reporting for higher education tuition and related expenses Section 3406 Mandatory presumption rules Amounts subject to withholding Determination of amounts to be withheld Interest and other income exempt from [section] 1441 withholding Effectively connected income Intermediaries Payments to U.S. branches of certain foreign banks or foreign insurance companies Partnerships Trusts and estates Special foreign exempt payees Claims for exemption or reduction of withholding tax under an income tax treaty General provisions relating to withholding agents Reporting of payments made and tax withheld under [section] 1461 Adjustments for overwithholding or underwithholding of tax Refunds or credits Withholding and reporting provisions of chapter 4 (sections 1471-1474) Working papers.
Digital File Characteristics
System Details Note
Mode of access: World Wide Web.
Source of Description
Title from title screen (viewed May 26, 2010).
Available in Other Form
Print version: Tello, Carol P., 1946- Payments directed outside the United States. Arlington, VA : Tax Management Inc