[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: 26CFR513.6]
[Page 60]
TITLE 26--INTERNAL REVENUE
CHAPTER 1--INTERNAL REVENUE SERVICE DEPARTMENT OF THE TREASURY
(Continued)
PART 513--IRELAND--Table of Contents
Subpart--Withholding of Tax
Sec. 513.6 Pensions and life annuities.
(a) Pensions, other than pensions paid by the Government of the
United States to individuals in respect of services rendered thereto in
the discharge of governmental functions, and any life annuity, derived
from sources within the United States in taxable years beginning on or
after January 1, 1951, by a nonresident alien individual who is resident
in Ireland for the purposes of Irish tax are exempt from United States
tax under the provisions of Article XII of the convention.
(b) To obviate withholding at the source in the case of such exempt
income the nonresident alien individual who is resident in Ireland for
the purposes of Irish tax shall notify the withholding agent by letter
in duplicate that such income is exempt from United States tax under the
provisions of Article XII of the convention. The letter of notification
shall be signed by the owner of the income, shall show the name and
address of both the payer and the owner, and shall contain a statement
that the owner, an individual, is neither a citizen nor a resident of
the United States but is resident in Ireland for the purposes of Irish
tax. This letter shall constitute authorization for the payment of such
income without deduction of the tax at source unless the Commissioner of
Internal Revenue subsequently notifies the withholding agent that the
tax should be withheld from payments of such income made after receipt
of such notice. If, after filing a letter of notification, the owner of
the income ceases to be eligible for the benefit of the convention, he
must promptly notify the withholding agent by letter in duplicate.
(c) Each letter of notification, or the duplicate thereof, must be
immediately forwarded by the withholding agent to the Commissioner of
Internal Revenue, Clearing Branch, Washington 25, D.C.