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SECTION 4. LIABILITY OF
Internal Revenue Bulletin 1997-48 · 2026-10-03 edition · updated 2026-10-04 · United States
WITHHOLDING AGENTS
Each person who makes a foreign-toforeign payment shall be treated as a withholding agent under section 1.1441–7 with respect to such payment. If a U.S. withholding agent withholds the highest rate of tax which would be imposed on all foreign recipients of dividends and substitute payments in a chain of such payments, each foreign withholding agent will be treated as having satisfied its withholding obligation under §1.1441–7.
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