Tax treatment liquidating distribution pfic

If for any reason the total amount of tax required to be deposited for any calendar year pursuant to the income tax return described in paragraph (c) of this section has not been deposited pursuant to § 1.6302-2, the withholding agent shall pay the balance of such tax due for such year at such place as the IRS shall specify.The tax shall be paid when filing the return described in paragraph (c)(1) of this section for such year, unless the IRS specifies otherwise. person and applies the rules described in § 1.1471-4(d)(2)(iii)(C) to the extent it fails to provide sufficient information regarding its account holders or payees, the withholding agent shall report the recipient of the payment as an unknown recipient to the extent recipient information is not provided and report the U. branch as provided in paragraph (d)(4)(ii)(A) of this section for an entity not treated as a recipient. withholding agent that makes payments of chapter 4 reportable amounts to an excepted or passive NFFE shall complete Forms 1042-S treating the NFFE as the recipient, except when the NFFE is a flow-through entity or acting as an intermediary and the partner or beneficiary is treated as the payee. withholding agent makes a payment of a chapter 4 reportable amount to a flow-through entity that is a passive NFFE, a nonparticipating FFI receiving a payment on behalf of an exempt beneficial owner, or a participating FFI or deemed-compliant FFI that is an NQI, NWP, or NWT, except as otherwise provided in paragraph (d)(4)(i)(B) of this section, the withholding agent must complete a separate Form 1042-S for each recipient that is a partner, beneficiary, owner, or account holder of such entity to the extent the withholding agent can reliably associate the payment with valid documentation (under the rules of § 1.1471-3(c) and (d)) provided by such entity, as applicable, with respect to each such recipient.Withholding certificates and other statements or information provided to a withholding agent are not required to be attached to the return. An amended return under this paragraph (c)(3) must be filed on Form 1042. See § 1.1471-2(a)(2)(i) for the requirement of a withholding agent to withhold on payments of U. source FDAP income made to a participating FFI or registered deemed-compliant FFI that is an NQI, NWP, or NWT. A withholding agent that is not a financial institution and that is required to file 250 or more Form 1042-S information returns for a taxable year must file Form 1042-S returns on magnetic media. A Form 1042 must be filed under this paragraph (c)(1) even if no tax was required to be withheld for chapter 4 purposes during the preceding calendar year. An amended return must include such information as the form or its accompanying instructions shall require, including, with respect to any information that has changed from the time of the filing of the return, the information that was shown on the original return and the corrected information. See also § 1.1471-2(a)(2)(iii) in the case of payments made to a QI. person, if the withholding agent treats amounts paid as effectively connected with the conduct of the branch's trade or business in the United States, or if the U. branch is the beneficial owner of the payment, the withholding agent must file Form 1042-S reporting the U. See § 301.6011-2(b) of this chapter for the requirements of a withholding agent that is not a financial institution with respect to the filing of Forms 1042-S on magnetic media. 610]§ 817A - Special rules for modified guaranteed contracts§ 832 - Insurance company taxable income§ 845 - Certain reinsurance agreements§ 846 - Discounted unpaid losses defined§ 848 - Capitalization of certain policy acquisition expenses§ 852 - Taxation of regulated investment companies and their shareholders§ 860E - Treatment of income in excess of daily accruals on residual interests§ 860G - Other definitions and special rules§ 863 - Special rules for determining source§ 864 - Definitions and special rules§ 865 - Source rules for personal property sales§ 874 - Allowance of deductions and credits§ 882 - Tax on income of foreign corporations connected with United States business§ 883 - Exclusions from gross income§ 884 - Branch profits tax§ 892 - Income of foreign governments and of international organizations§ 894 - Income affected by treaty§ 897 - Disposition of investment in United States real property§ 901 - Taxes of foreign countries and of possessions of United States§ 902 - Deemed paid credit where domestic corporation owns 10 percent or more of voting stock of foreign corporation§ 904 - Limitation on credit§ 907 - Special rules in case of foreign oil and gas income§ 911 - Citizens or residents of the United States living abroad§ 924§ 925§ 927§ 934 - Limitation on reduction in income tax liability incurred to the Virgin Islands§ 936 - Puerto Rico and possession tax credit§ 937 - Residence and source rules involving possessions§ 954 - Foreign base company income§ 956 - Investment of earnings in United States property§ 957 - Controlled foreign corporations; United States persons§ 960 - Special rules for foreign tax credit§ 963 - Repealed.

tax treatment liquidating distribution pfic-73tax treatment liquidating distribution pfic-54

The withholding agent must retain a copy of each Form 1042-S for the period of limitations on assessment and collection applicable to the tax reportable on the Form 1042 to which the Form 1042-S relates (determined as set forth in paragraph (c)(1) of this section). person that applies the rules described in § 1.1471-4(d)(2)(iii)(C) and that provides its withholding agent with sufficient information to determine the portion of the payment allocable to its reporting pools of recalcitrant account holders, payees that are nonparticipating FFIs, and payees that are U. persons described in paragraph (d)(4)(i)(B) of this section; An exempt beneficial owner of a payment, including when the payment is made to such owner through an FFI (including a nonparticipating FFI) that provides documentation and information sufficient for a withholding agent to determine the portion of the payment allocable to such owner; and Any other person required to be reported as a recipient by Form 1042-S, its accompanying instructions, under an FFI agreement, or paragraph (d)(4)(iii) of this section with respect to the Form 1042-S reporting requirements of a participating FFI. The Form 1042-S must include the following information, if applicable - The name, address, and EIN or GIIN (as applicable) of the withholding agent (as required on the instructions to the form) and the withholding agent's status for chapter 3 and chapter 4 purposes (as defined in the instructions to the form); A description of each category of income or payment made based on the income and payment codes provided on the form (for example, interest, dividends, and gross proceeds) and the aggregate amount in each category expressed in U. dollars; The rate and amount of withholding applied or, in the case of a payment of U. source FDAP income not subject to withholding and reportable under paragraph (d)(2)(i)(A) of this section, the basis for exempting the payment from withholding under chapter 4 based on exemption codes provided on the form); In the case of a payment to a person (including a flow-through entity or U. branch) for which the payment is reported as effectively connected with its conduct of a trade or business in the United States or, in the case of a U. A withholding agent is not required to report under paragraph (i)(1)(i) or (ii) of this section on a withholdable payment made to a participating FFI or reporting Model 1 FFI that is allocated to a payee that is an owner-documented FFI on an FFI withholding statement when the participating FFI or reporting Model 1 FFI includes on the statement the certification described in § 1.1471-3(c)(3)(iii)(B)( For the period from July 1 through December 31, 2014, the total of all withholdable payments made to the owner-documented FFI, and with respect to payments made after the 2014 calendar year, the total of all withholdable payments made to the owner-documented FFI during the calendar year; Beginning on July 1, 2014, in addition to the reporting on Form 1042-S required under paragraph (d)(4)(i)(E) of this section, a withholding agent (other than an FFI reporting accounts held by NFFEs under § 1.1471-4(d)) that makes a withholdable payment to, and receives information about any substantial U. owners of, a passive NFFE that is not an excepted NFFE as defined in § 1.1472-1(c) shall file a report with the IRS for the period from July 1 through December 31, 2014, and in each subsequent calendar year in which a withholdable payment is made with respect to any substantial U. A withholding agent is not required to report under this paragraph (i)(2) on a withholdable payment made to a participating FFI or a registered deemed-compliant FFI that is allocated to a payee that is a passive NFFE with one or more substantial U. owners on an FFI withholding statement when the participating FFI or registered deemed-compliant FFI includes on the statement the certification described in § 1.1471-3(c)(3)(iii)(B)(), provided that the withholding agent does not know or have reason to know that the certification is incorrect or unreliable. Adjustments to the total amount of tax withheld described in § 1.1474-2 shall be stated on the return as prescribed by the form and its accompanying instructions. person must exclude from Form 1042 payments made and taxes withheld by such U. The Form 1042-S shall be prepared in such manner as the form and its accompanying instructions prescribe. person as a payee for purposes of determining whether withholding is required under §§ 1.1471-2 and 1.1472-1. See paragraph (d)(4)(iii) of this section for the residual reporting responsibilities of an NQI, NWP, or NWT that is an FFI. A withholding agent that withholds based on a reasonable belief that such withholding is required under chapter 4 and the regulations thereunder is treated for purposes of section 1474 and this paragraph (f) as having withheld tax in accordance with the provisions of chapter 4 and the regulations thereunder. 2373]§ 467 - Certain payments for the use of property or services§ 468A - Special rules for nuclear decommissioning costs§ 468B - Special rules for designated settlement funds§ 469 - Passive activity losses and credits limited§ 471 - General rule for inventories§ 472 - Last-in, first-out inventories§ 475 - Mark to market accounting method for dealers in securities§ 481 - Adjustments required by changes in method of accounting§ 482 - Allocation of income and deductions among taxpayers§ 483 - Interest on certain deferred payments§ 493§ 504 - Status after organization ceases to qualify for exemption under section 501(c)(3) because of substantial lobbying or because of political activities§ 514 - Unrelated debt-financed income§ 527 - Political organizations§ 585 - Reserves for losses on loans of banks§ 597 - Treatment of transactions in which Federal financial assistance provided§ 642 - Special rules for credits and deductions§ 643 - Definitions applicable to subparts A, B, C, and D§ 645 - Certain revocable trusts treated as part of estate§ 663 - Special rules applicable to sections 661 and 662§ 664 - Charitable remainder trusts§ 672 - Definitions and rules§ 679 - Foreign trusts having one or more United States beneficiaries§ 701 - Partners, not partnership, subject to tax§ 702 - Income and credits of partner§ 703 - Partnership computations§ 704 - Partner’s distributive share§ 705 - Determination of basis of partner’s interest§ 706 - Taxable years of partner and partnership§ 707 - Transactions between partner and partnership§ 708 - Continuation of partnership§ 709 - Treatment of organization and syndication fees§ 721 - Nonrecognition of gain or loss on contribution§ 722 - Basis of contributing partner’s interest§ 723 - Basis of property contributed to partnership§ 724 - Character of gain or loss on contributed unrealized receivables, inventory items, and capital loss property§ 731 - Extent of recognition of gain or loss on distribution§ 732 - Basis of distributed property other than money§ 733 - Basis of distributee partner’s interest§ 734 - Adjustment to basis of undistributed partnership property where section 754 election or substantial basis reduction§ 735 - Character of gain or loss on disposition of distributed property§ 736 - Payments to a retiring partner or a deceased partner’s successor in interest§ 737 - Recognition of precontribution gain in case of certain distributions to contributing partner§ 741 - Recognition and character of gain or loss on sale or exchange§ 742 - Basis of transferee partner’s interest§ 743 - Special rules where section 754 election or substantial built-in loss§ 751 - Unrealized receivables and inventory items§ 752 - Treatment of certain liabilities§ 753 - Partner receiving income in respect of decedent§ 754 - Manner of electing optional adjustment to basis of partnership property§ 755 - Rules for allocation of basis§ 761 - Terms defined§ 809 - Repealed. A participating FFI or registered deemed-compliant FFI shall file Form 1042 in accordance with paragraph (c)(1) of this section to report chapter 4 reportable amounts for which the participating FFI or registered deemed-compliant FFI is required to file Form 1042-S, as described in paragraph (d)(4)(iii) of this section. One copy of the Form 1042-S shall be filed with the IRS on or before March 15 of the calendar year following the year in which the amount subject to reporting was paid, with a transmittal form as provided in the instructions to the form. A chapter 4 reportable amount does, however, include an amount paid to a participating FFI or registered deemed-compliant FFI to the extent allocable to its reporting pool of payees that are U. persons as described in paragraph (d)(4)(i)(B) of this section. This paragraph (f) does not relieve a withholding agent from tax liability under chapter 3 or chapter 4 or the regulations under those chapters. Form 8809-I, “Application of Extension of Time to File FATCA Form 8966,” (or such other form as the IRS may prescribe) must be used to request such extension of time and must be filed no later than the due date of Form 8966. Under certain hardship conditions, the IRS may grant an additional 90-day extension.

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