[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: 26CFR514.27]

[Page 85]
 
                       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. 514.27  Beneficiaries of domestic estate and trust.

    A nonresident alien individual who is a resident of France and a 
beneficiary of a domestic estate or trust shall be entitled to the 
exemption from, or reduction in rate of, United States tax granted by 
Articles 9, 10, 11, 13(1)(a), and 19 of the convention with respect to 
dividends, interest, royalties, and pensions, annuities, and alimony if 
he otherwise satisfies the requirements for exemption or reduction 
specified in the articles concerned, 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. However, such beneficiary 
is not entitled to the exemption from, or reduction in the rate of, U.S. 
tax granted by such articles to the extent that the trust conduit rules 
are not applicable to any payment received by the beneficiary such as, 
for example, a payment made out of the income of a trust established for 
the support and maintenance of a wife pursuant to a divorce decree. To 
obtain the exemption from, or reduction in the rate of, withholding of 
U.S. tax where permitted by this section, the beneficiary must, where 
applicable, execute and submit to the fiduciary of the estate or trust 
in the United States the appropriate letter of notification in the form 
prescribed in Sec. 514.23(c) (2) and (3), modified where necessary to 
indicate the type of income involved.

    Effective Date Note:  By T.D. 8734, 62 FR 53498, Oct. 14, 1997, 
Sec. 514.27 was removed, effective Jan. 1, 1999. By T.D. 8804, 63 FR 
72183, Dec. 31, 1998, the effective date was delayed until Jan. 1, 2000. 
By T.D. 8856, 64 FR 73408, Dec. 30, 1999, the effective date was delayed 
until Jan. 1, 2001.