Treas. Reg. 1.1441-6(b)(1): when a payer may apply a treaty rate (26 CFR 1.1441-6(b)(1))
The treaty rate is available only to the real beneficial owner of the fee who is resident in the treaty country and meets the treaty's other tests. A holder that routes the licence through a shell in another country does not qualify.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“The withholding imposed under section 1441, 1442, or 1443 on any payment to a foreign person is eligible for reduction under the terms of an income tax treaty only to the extent that such payment is treated as derived by a resident of an applicable treaty jurisdiction, such resident is a beneficial owner, and all other requirements for benefits under the treaty are satisfied.”
Where it was read
Figures it counts in
It is shown on its own, not counted into a figure.
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