specified financial institution payment

(2) Special rule where foreign financial institution is beneficial owner of payment (A) In general In the case of any tax properly deducted and withheld under section 1471 from a specified financial institution payment— (i) if the foreign financial institution referred to in subparagraph (B) with respect to such payment is entitled to a reduced rate of tax with respect to such payment by reason of any treaty obligation of the United States— (I) the amount of any credit or refund with respect to such tax shall not exceed the amount of credit or refund attributable to such reduction in rate, and (II) no interest shall be allowed or paid with respect to such credit or refund, and (ii) if such foreign financial institution is not so entitled, no credit or refund shall be allowed or paid with respect to such tax. (B) Specified financial institution payment The term “specified financial institution payment” means any payment if the beneficial owner of such payment is a foreign financial institution.

Source

26 USC § 1474(b)(2)

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Scoping language

None identified, default scope is assumed to be the parent (chapter 4) of this section.

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