Instructions For Form W-8imy - Certificate Of Foreign Intermediary, Foreign Flow-Through Entity, Or Certain U.s. Branches For United States Tax Withholding And Reporting Page 11

reporting Model 2 FFI), registered deemed-compliant FFI, or

$20 to NPFFI, a nonparticipating FFI that is an account

reporting Model 1 FFI, an account holder not withheld on

holder of the QI;

under chapter 4 or section 3406 who you report under

$10 each on behalf of two recalcitrant account holders of

chapter 4 or an applicable IGA (including the account

the QI ($20 total), each with U.S. indicia (as described in

holder’s TIN).

Regulations section 1.1441-7(b)(5)) associated with the

account;

An FFI withholding statement must also identify each

$5 each on behalf of A and B, U.S. individual account

intermediary or flow-through entity that is receiving a

holders of the QI that the QI reports as U.S. accounts

payment on behalf of a payee and include such entity’s

pursuant to its chapter 4 reporting obligations as a

chapter 4 status and GIIN (if applicable), excluding any

participating FFI ($10 total);

intermediary or flow-through entity that is an account holder

$10 on behalf of C, a U.S. exempt recipient that is not a

or interest holder in another QI, WP, or WT. An FFI

specified U.S. person and is an indirect account holder of the

withholding statement of a QI may combine withholding rate

QI (who beneficially owns the payment through an account

pool information provided by such an entity to the QI with

with another participating FFI);

withholding rate pools comprised of accounts that the QI

$20 on behalf of D, a U.S. non-exempt recipient that is a

maintains.

specified U.S. person who is an indirect account holder of the

If you are a QI that is not an FFI and that does not assume

QI (that beneficially owns the payment through an account

primary withholding responsibility under chapter 3 and

with a certified deemed-compliant FFI described in

chapter 4, you must provide, for a withholdable payment, a

Regulations section 1.1471-5(f)(2)); and

chapter 4 withholding statement that contains the name,

$10 each on behalf of two nonresident alien individuals

address, TIN (if any), entity type (if applicable), and chapter 4

who are account holders of the QI, one of whom is entitled to

status of each payee, the amount allocated to each payee, a

a 15% rate of withholding under an applicable income tax

valid withholding certificate or other documentation sufficient

treaty.

to establish the payee’s chapter 4 status. However, a

The dividend payment is both a withholdable payment

chapter 4 withholding statement may include pooled

under chapter 4 and a reportable amount under chapter 3.

information for payees that are nonparticipating FFIs that

The QI assumes primary withholding and reporting

hold accounts that you maintain or hold accounts with an

responsibility under chapter 3 and chapter 4 as well as

intermediary or flow-through entity receiving the payment

primary Form 1099 reporting and backup withholding

from you. You may also provide another pool of payees as

responsibility. As a result, the QI is not required to provide a

permitted under the chapter 4 regulations for a chapter 4

withholding statement allocating the payment to specific

withholding statement. See Regulations section 1.1471-3(c)

payees or withholding rate pools. The QI will provide Form

(3)(iii)(B).

W-8IMY and check boxes 14, 15a, and 15b.

For chapter 3 purposes. In the case of a reportable

amount that is a withholdable payment, any portion of the

Example 2. The facts are the same as Example 1,

payment for which you are acting as a QI that is not allocated

except QI is a non-U.S. payor under Regulations section

to a chapter 4 withholding rate pool or a U.S. non-exempt

1.6049-5(c)(5) and does not assume primary Form 1099 and

recipient (including for backup withholding purposes) must

backup withholding responsibility but reports the accounts of

be allocated to a chapter 3 withholding rate pool or pool of

A and B as U.S. accounts under Regulations section

U.S. exempt recipients, if it is not required to be separately

1.1471-4(d).

reported. The chapter 3 withholding rate pool may be

The QI must provide a withholding statement allocating

established by any reasonable method agreed upon by you

$20 of the payment to D, $10 to C, and $10 to a chapter 4

and the withholding agent. For example, you may agree to

withholding rate pool of U.S. payees. The QI need not

establish a separate account for a single chapter 3

allocate any portion of the payment specifically to A or B

withholding rate pool or you may agree to divide a payment

because the QI is a non-U.S. payor that is permitted to

made to a single account into portions allocable to each

include A and B in a chapter 4 withholding rate pool of U.S.

chapter 3 withholding rate pool. You must provide the

payees under Regulations section 1.6049-4(c)(4)(i). For

chapter 3 withholding rate pool information that is required for

payments made on or after April 1, 2017, see the instructions

the withholding agent to meet its withholding and reporting

to Part IV of this form for when a withholding statement

obligations. A withholding agent may request any information

includes an allocation of a payment of an amount subject to

reasonably necessary to withhold and report payments

chapter 3 withholding that is made to a pool of U.S. payees.

correctly.

The QI must also provide a Form W-9 (or alternatively, name

Form 1099 reporting. If you do not assume primary Form

and TIN) for D. A Form W-9 is not required for C. The QI will

1099 reporting and backup withholding responsibility, you

provide Form W-8IMY and check boxes 14, 15a, and 15d.

must provide payee specific information for each U.S.

Example 3. The facts are the same as Example 1, except

non-exempt recipient account holder (other than those U.S.

the QI is a U.S. payor and does not assume primary Form

payees included in a chapter 4 withholding rate pool of U.S.

1099 and backup withholding responsibility.

payees (described in Regulations section 1.6049-4(c)(4)(iii))

Because the QI is a U.S. payor, it is not permitted, under

or when the alternative procedure is used. The pools are

Regulations section 1.6049-4(c)(4)(i) and (iii), to include A

based on valid documentation that you obtain or, if a

and B in a chapter 4 withholding rate pool of U.S. payees.

payment cannot be reliably associated with valid

The QI must provide a withholding statement allocating $5 of

documentation, the applicable presumption rules.

the payment to A, $5 of the payment to B, $10 of the payment

Example 1. A QI that is a participating FFI receives a

to C, and $20 of the payment to D along with Forms W-9 (or

$100 payment of U.S. source dividends on an account for

name and TIN) for A, B, and D. The QI will provide Form

which it acts as a QI held with the withholding agent for the

W-8IMY and check boxes 14 and 15a.

following recipients:

-11-

Instructions for Form W-8IMY (Rev. 6-2017)

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