! amount of any tax on an item of income received

CAUTION by an entity that is treated as a domestic

corporation for U.S. tax purposes. Therefore, neither the domestic corporation nor its shareholders are entitled to the benefits of a reduction of U.S. income tax on an item of income received from U.S. sources by the corporation.

If you are an entity that derives the income as a

TIP resident of a treaty country, you must check the

box “No LOB article in treaty” if the applicable income tax treaty does not contain a “limitation on benefits” provision.

should also use this space to set out the requirements you meet under the identified treaty article.

The following are examples of persons who should complete this line:

Line 14c. If you are a foreign corporation claiming treaty benefits under an income tax treaty that entered into force before January 1, 1987 (and has not been renegotiated) on (1) U.S. source dividends paid to you by another foreign corporation or (2) U.S. source interest paid to you by a U.S. trade or business of another foreign corporation, you must generally be a “qualified resident” of a treaty country. See section 884 for the definition of interest paid by a U.S. trade or business of a foreign corporation (“branch interest”) and other applicable rules.

In general, a foreign corporation is a qualified resident of a country if any of the following apply:

• It meets a 50% ownership and base erosion test.

• It is primarily and regularly traded on an established securities market in its country of residence or the United States.

• It carries on an active trade or business in its country of residence.

• It gets a ruling from the IRS that it is a qualified resident. See Regulations section 1.884-5 for the requirements that must be met to satisfy each of these tests.

• Exempt organizations claiming treaty benefits under the exempt organization articles of the treaties with Canada, Mexico, Germany, and the Netherlands.

• Foreign corporations that are claiming a preferential rate applicable to dividends based on ownership of a specific percentage of stock in the entity paying the dividend and owning the stock for a specified period of time. Such persons should provide the percentage of ownership and the period of time they owned the stock. For example, under the United States-Italy treaty, to claim the 5% dividend rate, the Italian corporation must own 25% of the voting stock for a 12-month period. In addition, for example, if you qualify for and are claiming a zero rate on dividend payments under Article 10(3) of the United States-Germany income tax treaty, you should fill out line 15 with “Article 10(3),” “0,” and “dividends” in the spaces provided. In the space provided for an explanation, you may write that you are the beneficial owner of the dividends, you are a resident of Germany, you have directly owned shares representing 80% or more of the voting power of the company paying the dividends for the 12-month period ending on the date the entitlement to the dividend is determined, and that you satisfy the conditions of Article 28(2)(f)(aa) and (bb) and Article 28(4) of the treaty with respect to the dividends.

• Persons claiming treaty benefits on royalties if the treaty contains different withholding rates for different types of royalties.

• Persons claiming treaty benefits on interest other than the generally applicable rate. For example, under the United States-Australia treaty, the generally applicable interest rate is 10% under Article 11(2). However, interest may be exempt from withholding if the specific conditions under Article 11(3) are met.

• Persons claiming treaty benefits on business profits not attributable to a permanent establishment or on gains arising from the alienation of property (other than real property) that does not form all or part of a permanent establishment (including gains that do not arise from the alienation of a permanent establishment). For example, a foreign partner that derives gains subject to tax under section 864(c)(8) upon the transfer of an interest in a partnership that conducts a trade or business within the United States may claim treaty benefits on this form with respect to the withholding required under section 1446(f) by stating that the gains are not attributable to a permanent establishment and by including the relevant gains article of the treaty. Additionally, for a claim that gain or income with respect to a PTP interest is not attributable to a permanent establishment in the United States, you must identify the name of each PTP to which the claim relates. See, however, Regulations section 1.864(c) (8)-1(f) (providing that gain or loss on the alienation of a partnership interest is gain or loss attributable to the alienation of assets forming part of a permanent establishment to the extent that the assets deemed sold under section 864(c)(8) form part of a permanent establishment of the partnership).

If you are claiming treaty benefits under an