[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: 26CFR514.7]

[Page 69]
 
                       TITLE 26--INTERNAL REVENUE
 
     CHAPTER 1--INTERNAL REVENUE SERVICE DEPARTMENT OF THE TREASURY 
                               (Continued)
 
PART 514--FRANCE--Table of Contents
 
                       Subpart--Withholding of Tax
 
Sec. 514.7  Beneficiaries of a domestic estate or trust.

    (a) Entitled to benefits of convention. If he otherwise satisfies 
the requirements of the respective articles concerned, a nonresident 
alien individual who is a resident of France and who is a beneficiary of 
a domestic estate or trust shall be entitled to the reduction in the 
rate of, or exemption from, United States tax granted by Articles 6A and 
7 of the convention with respect to dividends, interest, and patent 
royalties and other like amounts to the extent that (1) any amount paid, 
credited, or required to be distributed by such estate or trust to such 
beneficiary is deemed to consist of such items, and (2) such items 
would, without regard to the convention, be includible in his gross 
income.
    (b) Withholding of United States tax. In order to be entitled, 
because of the application of paragraph (a) of this section, to the 
reduction in rate of, or exemption from, withholding of United States 
tax the beneficiary must otherwise satisfy the requirements of the 
respective articles concerned, and shall, where applicable, execute and 
submit to the fiduciary of the estate or trust in the United States the 
appropriate form or forms prescribed in Secs. 514.4(b) and 514.6(b).
    (c) Amounts otherwise includible in gross income of beneficiary. For 
the determination of amounts which, without regard to the convention, 
are includible in the gross income of the beneficiary, see subchapter J 
of chapter 1 of the Internal Revenue Code of 1954, and the regulations 
thereunder.

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