payee statement
(C)The term “payee statement” has the meaning given to such term by section 6724(d)(2). (D)This subsection shall not apply to any estate or trust. (k)For increase of limitation under subsection (a) for taxes paid with respect to amounts received which were included in the gross income of the taxpayer for a prior taxable year as a United States shareholder with respect to a controlled foreign corporation, see section 960(c).