Definitions

For purposes of this chapter— Except as otherwise provided by the Secretary— The term “withholdable payment” means— Such term shall not include any item of income which is taken into account under section 871(b)(1) or 882(a)(1) for the taxable year. Subparagraph (B) of section 861(a)(1) shall not apply. The term “substantial United States owner” means— in the case of a trust— In the case of any financial institution described in section 1471(d)(5)(C), clauses (i), (ii), and (iii) of subparagraph (A) shall be applied by substituting “0 percent” for “10 percent”. Except as otherwise provided by the Secretary, the term “specified United States person” means any United States person other than— any trust which— The term “withholding agent” means all persons, in whatever capacity acting, having the control, receipt, custody, disposal, or payment of any withholdable payment. The term “foreign entity” means any entity which is not a United States person.