Section 1.14721 provides rules for withholding when a withholding agent makes a payment to an NFFE, and defines categories of NFFEs that are not subject to withholding. Section 1.14716 defines classes of beneficial owners of payments that are exempt from withholding under chapter 4. Section 1.14715 defines terms relevant to section 1471 and the FFI agreement and defines categories of FFIs that will be deemed to have met the requirements of section 1471(b) pursuant to section 1471(b)(2).
Section 1.14714 describes the requirements of an FFI agreement under section 1471(b) and the application of sections 1471(b) and (c) to an expanded affiliated group of FFIs. Section 1.14713 provides rules for determining the payee of a payment and the documentation requirements to establish a payee's chapter 4 status. Section 1.14712 provides rules for withholding under section 1471(a) on payments to FFIs, including the exception from withholding for payments made with respect to certain grandfathered obligations. Section 1.14711 provides definitions for terms used in chapter 4 of the Internal Revenue Code (Code) and the regulations thereunder. Sections 1.14711 through 1.14747 provide rules for withholding when a withholding agent makes a payment to an FFI or NFFE and prescribe the requirements for and definitions relevant to FFIs and NFFEs to which withholding will not apply. Scope of chapter 4 of the Internal Revenue Code.