
You make these determinations based on the documentation and other information (contained in a withholding statement) that is associated with the flow-through entity's Form W-8IMY. For purposes of Chapter 4, you must determine the Chapter 4 status of the owners or beneficiaries of a flow-through entity (subject to the exceptions described above), how much of the payment relates to each owner or beneficiary, and whether withholding under Chapter 4 applies.

or foreign persons, how much of the payment relates to each owner or beneficiary, and, if the owner or beneficiary is foreign, whether a reduced rate of Chapter 3 withholding applies. You may also be required to treat the entity as a flow-through entity under the presumption rules.įor purposes of Chapter 3, you must determine whether the owners or beneficiaries of a flow-through entity are U.S. Generally, you treat a payee as a flow-through entity if it provides you with a Form W-8IMY on which it claims such status. If you make a withholdable payment to a flow-through entity that is not one of the types described above, you must treat the partner, beneficiary, or owner (as applicable) of the flow-through entity as the payee for Chapter 4 purposes (similar to the determination of the payee for Chapter 3 purposes) (looking through partners, beneficiaries, and owners that are themselves flow-through entities that are not one of the types described above).

If the Chapter 3 payee is a disregarded entity or flow-through entity for U.S. A foreign simple or foreign grantor trust (other than a withholding foreign trust)
