[Code of Federal Regulations]
[Title 26, Volume 20]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR601.206]

[Page 92-93]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 601_STATEMENT OF PROCEDURAL RULES--Table of Contents
 
              Subpart B_Rulings and Other Specific Matters
 
Sec. 601.206  Certification required to obtain reduced foreign tax rates 
under income tax treaties.

    (a) Basis of certification. Most of the income tax treaties between 
the United States and foreign countries provide for either a reduction 
in the statutory rate of tax or an exemption from tax on certain types 
of income received from sources within the foreign treaty country by 
citizens, domestic corporations, and residents of the United States. 
Some of the treaty countries reduce the withholding tax on such types of 
income or exempt the income from withholding tax after the claimant 
furnishes evidence that he is entitled to the benefits of the treaty. 
Other countries initially withhold the tax at statutory rates and refund 
the excess tax withheld after satisfactory evidence of U.S. residence 
has been accepted. As part of the proof that the applicant is a resident 
of the United States and thus entitled to the benefits of the treaty, he 
must usually furnish a certification from the U.S. Government that he 
has filed a U.S. income tax return as a citizen, domestic corporation, 
or resident of the United States.
    (b) Procedure for obtaining the certification. Most of the treaty 
countries which require certification have printed special forms. The 
forms contain a series of questions to be answered by the taxpayer 
claiming the benefits of the treaty, followed by a statement which the 
foreign governments use for the U.S. taxing authority's certification. 
This certification may be obtained from the office of the district 
director of the district in which the claimant filed his latest income 
tax return. Some certification forms are acceptable for Service 
execution; however, others cannot be executed by the Service without 
revision. In these instances the office of the district director will 
prepare its own document of certification in accordance with internal 
instructions. This procedure has been accepted by most treaty countries 
as a satisfactory substitute.
    (c) Obtaining the official certification forms. The forms may be 
obtained from the foreign payor, the tax authority of

[[Page 93]]

the treaty country involved, or the District Office, Foreign Operations 
District.

[34 FR 14601, Sept. 19, 1969, as amended at 49 FR 36500, Sept. 18, 1984]

Subpart C [Reserved]