26 U.S. Code § 1472 - Withholdable payments to other foreign entities
(a) In general
In the case of any withholdable payment to a non-financial foreign entity, if—
(1) the beneficial owner of such payment is such entity or any other non-financial foreign entity, and
then the withholding agent with respect to such payment shall deduct and withhold from such payment a tax equal to 30 percent of the amount of such payment.
(b) Requirements for waiver of withholding
The requirements of this subsection are met with respect to the beneficial owner of a payment if—
(1) such beneficial owner or the payee provides the withholding agent with either—
(A) a certification that such beneficial owner does not have any substantial United States owners, or
(2) the withholding agent does not know, or have reason to know, that any information provided under paragraph (1) is incorrect, and
Subsection (a) shall not apply to—
(1) except as otherwise provided by the Secretary, any payment beneficially owned by—
(B) any corporation which is a member of the same expanded affiliated group (as defined in section 1471 (e)(2) without regard to the last sentence thereof) as a corporation described in subparagraph (A),
(C) any entity which is organized under the laws of a possession of the United States and which is wholly owned by one or more bona fide residents (as defined in section 937(a)) of such possession,
(D) any foreign government, any political subdivision of a foreign government, or any wholly owned agency or instrumentality of any one or more of the foregoing,
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