Issuer
Definition: An Issuer is an entity (not a human or natural person), such as a corporation, trust, or government, that develops, registers, and sells securities. … Read More »Issuer
Tye Burroughs
Intermediary
Definition: An intermediary is a custodian, broker, nominee, middleman,or any other person that acts as an agent for another person. A non-US (foreign) intermediary is… Read More »Intermediary
Interest that is not Portfolio Interest
Definition: Interest that appears to qualify as portfolio interest based on the above definition will not qualify as portfolio interest if it is contingent interest or if… Read More »Interest that is not Portfolio Interest
Interest
Definition: The residence of the payor (also referred to as debtor) determines the source of interest income. Interest payments from U.S. residents and U.S. corporations… Read More »Interest
Insufficient Documentation
Definition: If the Service determines that a withholding agent relied on insufficient documentation and had actual knowledge or reason to know that a claim of… Read More »Insufficient Documentation
Information Return vs Tax Return
Definition: In General Counsel Memorandum (GCM) 36372 Application of Section 6652(d) Penalty to Incomplete Forms 990-P and 4848, the Service considered whether section 6652(d)(1) would… Read More »Information Return vs Tax Return
Income
Definition: The Internal Revenue Code (IRC) defines general category income as income other than passive income. It also includes income that does not fall into… Read More »Income
Hybrid Entities
Definition: A hybrid entity is an entity that is considered to be a pass-through entity for U.S. tax purposes and a taxable corporate entity (association) in the… Read More »Hybrid Entities
Green Card Test
Definition: The green card test considers a person to be resident for U.S. federal tax purposes if he or she is a Lawful Permanent Resident… Read More »Green Card Test
Grantor Trust
Definition: A Grantor Trust is a trust that has a grantor who retains interest or control of the trust. The grantor is subject to anti-abuse… Read More »Grantor Trust