[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: 26CFR514.3]

[Page 66-67]
 
                       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. 514.3  Dividends received by addressee not actual owner.

    (a) Additional tax to be withheld--(1) Nominee or representative. 
The recipient in France of any dividend, paid on or

[[Page 67]]

after January 1, 1957, from which United States tax at the reduced rate 
of 15 percent has been withheld at source pursuant to Sec. 514.2(c)(1), 
who is a nominee or representative through whom the dividend is received 
by a person other than one described in Sec. 514.2(a) as being entitled 
to the reduced rate, shall withhold an additional amount of United 
States tax equivalent to the United States tax which would have been 
withheld if the convention had not been in effect (30 percent as of the 
date of approval of Secs. 514.1 to 514.10) minus the 15 percent which 
has been withheld at the source.
    (2) Fiduciary or partnership. A fiduciary or a partnership with an 
address in France which receives, otherwise than as a nominee or 
representative, a dividend from which United States tax at the reduced 
rate of 15 percent has been withheld at source pursuant to Sec. 514.2 
shall withhold an additional amount of United States tax from the 
portion of the dividend included in the gross income from sources within 
the United States of any beneficiary or partner, as the case may be, who 
is not entitled to the reduced rate of tax in accordance with 
Sec. 514.2(c). The amount of the additional tax is to be calculated in 
the same manner as under subparagraph (1) of this paragraph.
    (3) Released amounts of tax. If any amount of United States tax is 
released pursuant to Sec. 514.8(a)(1) by the withholding agent in the 
United States with respect to a dividend paid to a nominee, 
representative, fiduciary, or partnership with an address in France, the 
latter shall withhold from such released amount any additional amount of 
United States tax, otherwise required to be withheld from the dividend 
by the provisions of subparagraphs (1) and (2) of this paragraph, in the 
same manner as if at the time of payment of the dividends United States 
tax at the rate of only 15 percent had been withheld at source 
therefrom.
    (b) Returns filed by French withholding agents. The amounts withheld 
pursuant to paragraph (a) of this section by any withholding agent in 
France shall be deposited, without converting the amounts into United 
States dollars, with the Directeur General des Impots of France on or 
before the 15th day after the close of the quarter of the calendar year 
in which the withholding in France occurs. The withholding agent making 
the deposit shall render therewith such appropriate French form as may 
be prescribed by the Directeur General des Impots. The amounts so 
deposited should be remitted by the Directeur General des Impots by 
draft in the United States dollars to the Director, International 
Operations Division, Internal Revenue Service, Washington 25, D. C., U. 
S. A., on or before the end of the calendar month in which the deposit 
is made, and should be accompanied by such French form as may be 
required to be rendered by the withholding agent in France in connection 
with the deposit.