For purposes of this chapter—
(1) Withholdable paymentExcept as otherwise provided by the Secretary—
(A) In generalThe term “withholdable payment” means—
(i)
any payment of interest (including any original issue discount), dividends, rents, salaries, wages, premiums, annuities, compensations, remunerations, emoluments, and other fixed or determinable annual or periodical gains, profits, and income, if such payment is from sources within the United States, and
(C) Special rule for sourcing interest paid by foreign branches of domestic financial institutions
Subparagraph (B) of section 861(a)(1) shall not apply.
(2) Substantial United States owner
(A) In generalThe term “substantial United States owner” means—
(i)
with respect to any corporation, any specified United States person which owns, directly or indirectly, more than 10 percent of the stock of such corporation (by vote or value),
(ii)
with respect to any partnership, any specified United States person which owns, directly or indirectly, more than 10 percent of the profits interests or capital interests in such partnership, and
(iii) in the case of a trust—
(I)
any specified United States person treated as an owner of any portion of such trust under subpart E of part I of subchapter J of chapter 1, and
(II)
to the extent provided by the Secretary in regulations or other guidance, any specified United States person which holds, directly or indirectly, more than 10 percent of the beneficial interests of such trust.
(3) Specified United States personExcept as otherwise provided by the Secretary, the term “specified United States person” means any United States person other than—
(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 the stock of which is regularly traded on an established securities market,
(4) Withholding agent
The term “withholding agent” means all persons, in whatever capacity acting, having the control, receipt, custody, disposal, or payment of any withholdable payment.