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
KB 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
Documentation Furnished After Payment
Definition: When a payee or beneficial owner provides documentation after a payment is made it is considered late. The Service may accept late documentation if… Read More »Documentation Furnished After Payment
Documentation
Definition: In general, if a payment is subject to withholding a withholding agent must withhold 30% of the payment unless it can reliably associate the… Read More »Documentation
Treaty Benefits
Definition: The concept of withholding tax on payments to nonresident alien individuals and foreign corporations applies to U.S. source FDAP income that is not effectively… Read More »Treaty Benefits