[Code of Federal Regulations]
[Title 26, Volume 18, Parts 500 to 599]
[Revised as of April 1, 2000]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR517.6]

[Page 119]
 
                       TITLE 26--INTERNAL REVENUE
 
     CHAPTER 1--INTERNAL REVENUE SERVICE DEPARTMENT OF THE TREASURY 
                               (Continued)
 
PART 517--PAKISTAN--Table of Contents
 
                       Subpart--Withholding of Tax
 
Sec. 517.6  Beneficiaries of a domestic estate or trust.

    A nonresident alien individual who is resident in Pakistan for the 
purposes of Pakistan tax and who is a beneficiary of a domestic estate 
or trust shall be entitled to the exemption from United States tax 
granted by Article VIII of the convention with respect to patent and 
copyright royalties to the extent that (a) any amount paid, credited, or 
required to be distributed by the estate or trust to the beneficiary is 
deemed to consist of those items and (b) the items so deemed to be 
included in such amount would, without regard to the convention, be 
includible in his gross income; provided, however, that the beneficiary 
otherwise satisfies the requirements for exemption specified in Article 
VIII of the convention. To obtain the exemption from withholding of 
United States tax in such a case, the beneficiary must execute and 
submit to the fiduciary of the estate or trust in the United States the 
letter of notification prescribed in Sec. 517.3(b).