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 6

Qualified derivatives dealer (QDD). A QDD is a

redemption) of a short-term obligation that is effected outside

qualified intermediary that is an eligible entity that agrees to

the United States. It also does not include amounts of original

meet the requirements of Regulations section 1.1441-1(e)(6)

issue discount arising from a sale and repurchase transaction

(i) and the QI agreement. An eligible entity is defined in

completed within a period of 2 weeks or less, or amounts

Regulations section 1.1441-1(e)(6)(ii).

described in Regulations section 1.6049-5(b)(7), (10), or (11)

(relating to certain obligations issued in bearer form).

To act as a QDD, the home office or branch, as

applicable, must qualify and be approved for QDD status and

Reverse hybrid entity. A reverse hybrid entity is any

must represent itself as a QDD on its Form W-8IMY and

person (other than an individual) that is not fiscally

separately identify the home office or branch as a recipient

transparent under U.S. tax law principles but that is fiscally

on a withholding statement (if required). Each home office or

transparent under the laws of a jurisdiction with which the

branch that obtains QDD status is treated as a separate

United States has an income tax treaty.

QDD.

Territory financial institution. The term territory financial

Qualified securities lender (QSL). Notice 2010-46,

institution means a financial institution that is incorporated or

available at IRS.gov/irb/2010-24_IRB/ar09.html, provided

organized under the laws of any U.S. territory. However, an

rules for QSLs acting with respect to payments of substitute

investment entity that is not also a depository institution,

dividends. A QSL should certify to its QSL status in Part III of

custodial institution, or specified insurance company is not a

this form, even if it is not a qualified intermediary. An entity

territory financial institution. A territory financial institution

will no longer be able to claim QSL status as of January 1,

acting as an intermediary or that is a flow-through entity may

2018.

agree to be treated as a U.S. person under Regulations

Nonqualified intermediary. A nonqualified intermediary

section 1.1441-1(b)(2)(iv)(A).

is any intermediary that is not a U.S. person and that is not a

Withholdable payment. The term withholdable payment is

qualified intermediary.

defined in Regulations section 1.1473-1(a).

Nonreporting IGA FFI. A nonreporting IGA FFI is an FFI

Withholding agent. Any person, U.S. or foreign, that has

that is a resident of, or located or established in, a Model 1 or

control, receipt, custody, disposal, or payment of U.S. source

Model 2 IGA jurisdiction that meets the requirements of:

FDAP income subject to chapter 3 or a withholdable payment

A nonreporting financial institution described in a specific

under chapter 4 is a withholding agent. The withholding

category in Annex II of the Model 1 or Model 2 IGA;

agent may be an individual, corporation, partnership, trust,

A registered deemed-compliant FFI described in

association, or any other entity, including (but not limited to)

Regulations section 1.1471-5(f)(1)(i)(A) through (F);

any foreign intermediary, foreign partnership, and U.S.

A certified deemed-compliant FFI described in

branches of certain foreign banks and insurance companies.

Regulations section 1.1471-5(f)(2)(i) through (v); or

An exempt beneficial owner described in Regulations

For purposes of section 1446, the withholding agent is the

section 1.1471-6.

partnership conducting the trade or business in the United

States. For a publicly traded partnership, the withholding

Nonwithholding foreign partnership, simple trust, or

agent may be the partnership, a nominee holding an interest

grantor trust. A nonwithholding foreign partnership is any

on behalf of a foreign person, or both. See Regulations

foreign partnership other than a withholding foreign

sections 1.1446-1 through 1.1446-6.

partnership. A nonwithholding foreign simple trust is any

foreign simple trust that is not a withholding foreign trust. A

Withholding foreign partnership (WP) or withholding

nonwithholding foreign grantor trust is any foreign grantor

foreign trust (WT). A WP or WT is a foreign partnership or

trust that is not a withholding foreign trust.

a foreign simple or grantor trust that has entered into a

withholding agreement with the IRS in which it agrees to

Participating FFI. A participating FFI is an FFI that has

assume primary withholding responsibility for purposes of

agreed to comply with the terms of an FFI agreement with

chapter 4 and under sections 1441 and 1442 for all payments

respect to all branches of the FFI, other than a branch that is

that are made to its partners, beneficiaries, or owners, except

a reporting Model 1 FFI or a U.S. branch. The term

as otherwise provided in the withholding agreement. A WP

participating FFI also includes a reporting Model 2 FFI and a

also includes a foreign reverse hybrid entity that has entered

QI branch of a U.S. financial institution, unless such branch is

into a withholding agreement.

a reporting Model 1 FFI.

Withholding statement. A withholding statement provides

Payee. A payee is generally a person to whom a payment is

an allocation (by income type) to each payee (or withholding

made, regardless of whether such person is the beneficial

rate pool, if applicable, or other pool of payees to the extent

owner. For a payment made to a financial account, the payee

permitted under the chapter 3 or 4 regulations) of each

is generally the holder of the financial account. However,

payment an intermediary or flow-through entity receives. The

under certain circumstances a person who receives a

withholding statement forms an integral part of the

payment will not be considered the payee. For purposes of

withholding certificate, and the penalties of perjury statement

chapter 3, see Regulations section 1.1441-1(b)(2) and for

provided on the withholding certificate shall apply to the

chapter 4, see Regulations section 1.1471-3(a)(3).

withholding statement. The withholding statement may be

Reportable amount. Solely for purposes of the statements

provided in any manner upon which the intermediary or the

required to be attached to Form W-8IMY, a reportable

flow-through entity and the withholding agent mutually agree,

amount is an amount subject to withholding under chapter 3,

including electronically if certain safeguards concerning

U.S. source deposit interest (including original issue

electronic transmission are met. A withholding statement also

discount), and U.S. source interest or original issue discount

provides information required for purposes of chapter 4 if the

on the redemption of short-term obligations. It does not

intermediary or flow-through entity is receiving a withholdable

include payments on deposits with banks and other financial

payment, in which case the entity must provide an FFI

institutions that remain on deposit for 2 weeks or less or

withholding statement, chapter 4 withholding statement, or

amounts received from the sale or exchange (other than a

-6-

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

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