[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: 26CFR513.10]

[Page 63]
 
                       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. 513.10  Beneficiaries of a domestic estate or trust.

    A nonresident alien who is resident in Ireland for the purposes of 
Irish tax and who is a beneficiary of a domestic estate or trust shall 
be entitled to the exemption from, or reduction in the rate of, United 
States tax provided in Articles VI, VII, VIII, IX, and XV of the 
convention with respect to dividends, interest, royalties, natural 
resource royalties, and real property rentals to the extent such item or 
items are included in his share of the distributed or distributable 
income of such estate or trust. In order to be entitled in such instance 
to the exemption from, or reduction in the rate of, tax such beneficiary 
must otherwise satisfy the requirements of these respective Articles of 
the convention and must, where applicable, execute and submit to the 
fiduciary of such estate or trust in the United States the appropriate 
letter of notification prescribed in Secs. 513.3(b), 513.4, and 513.5.