IRC 1441 150 Withholding of Tax on NRAIRC 1442 150 Withholding of Tax on IRC 1445 150 Withholding of Tax on IRC 1446 150 Withholding of Tax on ECI Withholding of Tax on NRAs and Foreign Corps 1 ID: 899617
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1 Reporting and Withholding on Payments to
Reporting and Withholding on Payments to Foreign Persons A Technical Overview IRC § 1441 – Withholding of Tax on NRAIRC § 1442 – Withholding of Tax on IRC § 1
2 445 – Withholding of Tax on IRC §
445 – Withholding of Tax on IRC § 1446 – Withholding of Tax on ECI Withholding of Tax on NRAs and Foreign Corps - 1441/1442Income Must Be:US sourced per sourcin
3 g rules (FDAP) Generally not effectivel
g rules (FDAP) Generally not effectively connected with a US trade or business Personal services Where performedDividends U.S. / For. Corp. Interest Re
4 sidence/payer Rents
sidence/payer Rents Location of prop. Foreign PersonsNonresident Alien IndividualForeign corporation, Foreign PartnershipForeign Trusts & Foreign Esta
5 tesAny other person that is not a U.S. p
tesAny other person that is not a U.S. person Withholding Agent - control, W-8EXP- Beneficial Owner status Form W-8IMY – Non Beneficial Withholding Rates and Reporti
6 ng Requirements 1441/1442Withholding ra
ng Requirements 1441/1442Withholding rate of 30% is generally required on Gross Income.Reduced treaty rate, including exemption from tax may apply.File withholding tax ret
7 urn Forms 1042 and 1042-S. Withholding o
urn Forms 1042 and 1042-S. Withholding on Disposition of USRPI by Foreign Persons – IRC § 144510% withholding on the amount realized10% withholding may be reduced Wit
8 hholding must be submitted to the IRS by
hholding must be submitted to the IRS by the 20th day of the date of transferForeign seller/transferor must file Form 1040NR or 1120F US Real Property Holding CorporationsF
9 MV of its USRPI is at least 50% of its U
MV of its USRPI is at least 50% of its USRPI plus FRPI plus Bus Assets.If corporation is a USRPHC, any interest in that corporation is a USRPI If USRPHC disposes of USRPI i
10 n private corporation FIRPTA applies to
n private corporation FIRPTA applies to foreign SHs With publicly traded corporation, FIRPTA applies to any 5% or greater shareholder . Partnership Withholding – IRC Â
11 § 1446If a partnership has ECI, andAny p
§ 1446If a partnership has ECI, andAny portion of that ECI is allocable to a foreign partner,That partnership is subject to a withholding tax at the highest rate for that f
12 oreign partner small/international/inde
oreign partner small/international/index.htmlBob Driscoll – Withholding Technical AdvisorTom Logan – Withholding Technical Advisor Form W-8IMY – Non Benefi