branch constitutes income that is effectively connected with a U.S. See also paragraph (f)(6) of this section for the rules under which a withholding agent can presume a payment to a U.S. person must furnish a withholding certificate on a Form W–8 to certify its chapter 4 status (and not a Form W–9, “Request for Taxpayer Identification Number and Certification”). person for purposes of the withholding certificate it may provide to a withholding agent for purposes of chapter 4. person, however, is not treated as a U.S. A withholding agent that makes a payment to a limited branch (including an entity disregarded as a separate entity from its owner if such owner is an FFI and the disregarded entity is unable to comply with the terms of an FFI agreement with respect to accounts that it maintains) will be required to treat the payment as being made to a nonparticipating FFI. The rules under § 1.1471–3(d)(4) and (e)(3) apply to determine the circumstances under which a withholding agent may treat a payment made to a disregarded entity owned by an FFI as made to a payee that is a participating FFI or registered deemed-compliant FFI, and not as a payment made to a payee that is a nonparticipating FFI. federal tax purposes under § 301.7701–2(c)(2)(i) of this chapter as an entity separate from its single owner must treat the single owner as the payee. Except as otherwise provided in paragraph (a)(3)(v) through (vii) of this section, a withholding agent that makes a withholdable payment to an entity that is disregarded for U.S. (v ) Disregarded entity or limited branch.
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