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(B) The withholding person may demonstrate, to the satisfaction of the District Director or Assistant Commissioner (International), that the reasonable amount of tax, if any, was actually paid to the IRS; C) Proof of commitments at sea. If the detaining party receives valid evidence as described in § 1.6049-5(c)(1) or (c)(4) with respect to an offshore obligation of a company, but the evidence does not prove the classification of the company as a company, trust, estate or partnership, the retention agent may (in the absence of actual knowledge) assume that the company is the type of person registered in accordance with § 1.6049-4(c) ( 1) (ii) (B) to (Q) if it is able to do so, if it can be treated in accordance with any of these paragraphs without the need to document it. If the withholding agent cannot treat a beneficiary as a person described in § 1.6049-4 (c) (1) (ii) (B) to (Q), the beneficiary will be considered a corporation unless the withholding agent knows or has reason to know that the company is not classified as a corporation for U.S. tax purposes. If a beneficiary is or is presumed to be a corporation within the meaning of subparagraph (b) (3) (ii) (C) of this paragraph and a foreign person under subparagraph (b) (3) (iii) of this article, a withholding agent shall not treat the beneficiary as the beneficial owner of the income if the person retaining the source knows or has reason to believe that the beneficiary is not the beneficial owner of the income. For this purpose, a retainer has reason to believe that the beneficiary is not a beneficial owner if the evidence shows that the beneficiary is a bank, broker, intermediary, custodian or other agent or is treated as such in accordance with § 1.6049-4 (c) (1) (ii) (B) to (Q). However, a refusnik may treat that person as a beneficial owner if the alien submits a written declaration signed by a person authorized to sign the declaration, which is attached to the written proof and which shows that the foreign person is the beneficial owner of the income. See paragraph (e)(5)(iv) of this section (which requires that a qualified intermediary who assumes responsibility for the primary source in accordance with Chapter 3 assume responsibility for the primary source in accordance with Chapter 4). See also paragraph (e)(5)(v)(C)(3) of this section for alternative methods of allocating payments to U.S. persons who are not exempt recipients, and subsection (e)(5)(v)(C)(1) and (2) of this Section, where a qualified intermediary may provide a withholding agent with a pool of withholding rates under Chapter 4 of U.S. beneficiaries instead of documents relating to each U.S. beneficiary not exempt.
(i) where the point of detention actually knows the identification number of the beneficiary`s employer and that number begins with the two digits “98”; (1) In the case of a payment to an unqualified intermediary, transit company (as defined in paragraph (c)(23) of this Section) or a U.S. branch pursuant to subsection (b) (2) (iv) of this Section (other than a U.S. branch) B. treated as a U.S. person), a hold agent can reliably link the payment to valid documents only to the extent that the hold agent makes the payment prior to payment to a valid unqualified person. intermediary, a direct flow unit or an American company.
