26 USC 1474 - Special rules

U.S Code last checked for updates: May 02, 2024

§ 1474.

Special rules

(a)

Liability for withheld tax

(b)

Credits and refunds

(1)

In general

(2)

Special rule where foreign financial institution is beneficial owner of payment

(A)

In general

In the case of any tax properly deducted and withheld under section 1471 from a specified financial institution payment—

(i)

if the foreign financial institution referred to in subparagraph (B) with respect to such payment is entitled to a reduced rate of tax with respect to such payment by reason of any treaty obligation of the United States—

(I)

the amount of any credit or refund with respect to such tax shall not exceed the amount of credit or refund attributable to such reduction in rate, and

(II)

no interest shall be allowed or paid with respect to such credit or refund, and

(ii)

if such foreign financial institution is not so entitled, no credit or refund shall be allowed or paid with respect to such tax.

(B)

Specified financial institution payment

(3)

Requirement to identify substantial United States owners

(c)

Confidentiality of information

(1)

In general

(2)

Disclosure of list of participating foreign financial institutions permitted

(d)

Coordination with other withholding provisions

(e)

Treatment of withholding under agreements

(f)

Regulations

(Added Pub. L. 111–147, title V, § 501(a), Mar. 18, 2010, 124 Stat. 104.)

cite as: 26 USC 1474