[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: 26CFR513.8]

[Page 62]
 
                       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. 513.8  Addressee not actual owner.

    (a) If any person with an address in Ireland who receives a dividend 
from a United States corporation with respect to which United States tax 
at the rate of only 15 percent has been withheld at source is a nominee 
or representative through whom such dividend flows to a person other 
than one described in Sec. 513.2(a) as being entitled to such reduced 
rate of 15 percent, such recipient in Ireland will withhold an 
additional amount of United States tax equivalent to the difference 
between the United States tax which would have been withheld had the 
convention not been in effect (30 percent as of the date of approval of 
this subpart) and the 15 percent withheld at the source with respect to 
such dividend pursuant to Sec. 513.2(d).
    (b) In any case in which a fiduciary or partnership with an address 
in Ireland receives, otherwise than as a nominee or representative, a 
dividend from a United States corporation with respect to which United 
States tax at the rate of only 15 percent has been withheld at source, 
if a beneficiary of such fiduciary or a partner in such partnership is 
not entitled to the reduced rate of tax provided in Article VI(1) of the 
convention, the fiduciary or partnership will withhold an additional 
amount of United States tax with respect to the portion of such dividend 
included in such beneficiary's share of the distributed or distributable 
income, or in such partner's distributive share of the income, of such 
fiduciary or partnership, as the case may be. The amount of the 
additional tax is to be calculated in the same manner as under paragraph 
(a) of this section.
    (c) If any amount of United States tax is released pursuant to 
Sec. 513.7(a) by the withholding agent in the United States with respect 
to a dividend received by such a person with an address in Ireland, the 
latter will also withhold from such released amount any additional 
amount of United States tax, otherwise required to be withheld by the 
preceding provisions of this section in respect of such dividend, in the 
same manner as if at the time of payment of such dividend United States 
tax at the rate of only 15 percent had been withheld at source 
therefrom.
    (d) The amounts so withheld by such withholding agents in Ireland 
will be deposited, without converting such amounts into United States 
dollars, with the Irish Revenue Commissioners on or before the 15th day 
after the close of the calendar year quarter in which such withholding 
in Ireland occurs. Each withholding agent making such deposit will 
render therewith the appropriate Irish form as prescribed in regulations 
made by the Revenue Commissioners. The Revenue Commissioners have 
arranged that the amounts so deposited will be remitted by draft in 
United States dollars to the District Director of Internal Revenue, 
Baltimore, Maryland, U.S.A., on or before the end of the calendar month 
in which the deposits are made, such draft to be accompanied by the 
Irish form rendered by the withholding agents in Ireland in connection 
with such deposits.