Publication 1187›Part A›General Information›INTENTIONALLY LEFT BLAN K
Sec. 11 Definition of Terms
0925 Publ 1187 (PDF) · 2026-10-03 edition · updated 2026-10-04 · United States
| Element Amendment Number |
Description Any amended form must have the same unique form identifier as the original form that is being amended. Each time that you amend the same form (as determined by the unique form identifier), you must provide the amendment number in the box provided on the form (using “1” for the first amendment and increasing sequentially for each subsequent amendment). For additional information see Instructions for Form 1042-S. |
|---|---|
| Amended Return | An amended return is an information return filed by the transmitter to amend an information return that was previously filed and processed by the IRS but contained erroneous information. |
| Amount Subject to Chapter 3 Withholding |
Generally, an amount subject to Chapter 3 withholding is an amount from sources within the United States that is fixed determinable annual or periodical (FDAP) income. FDAP income is all income included in gross income, including interest, dividends, rents, royalties, and compensation. Amounts subject to Chapter 3 withholding do not include amounts that are not FDAP, such as most gains from the sale of property, as well as other specific items of income specifically excluded. See Regulations section 1.1441-2. |
| Beneficial Owner | The beneficial owner of income is, generally, the person who is required under U.S. tax principles to include the income in gross income. For additional information and special conditions see definitions in theInstructions for Form 1042-S. |
| Employer Identification Number (EIN) |
An Employer Identification Number is a nine-digit number assigned by the IRS for federal tax reporting purposes. |
| File | For purpose of this publication, a file consists of one Transmitter “T” Record at the beginning of the file, a Withholding agent “W” Record, followed by the Recipient “Q” Record(s), a Reconciliation “C” Record summarizing the number of preceding “Q” Records and total of preceding money fields. Follow with any additional “W”, “Q”, and “C” Record sequences as needed. The last record on the file is the End of Transmission “F” Record. Nothing should be reported after the End of Transmission “F” Record. |
| Filing Year | The calendar year in which the information returns are being filed with the IRS. |
| Flow Through Entity (FTE) |
A foreign partnership (other than a withholding foreign partnership) or a foreign simple or grantor trust (other than a withholding foreign trust). For any payments for which a reduced rate of withholding under an income tax treaty is claimed, an entity is a flow-through entity if it is considered to be fiscally transparent under IRC Section 894 with respect to the payment by an interest holder’s jurisdiction. |
| Foreign Financial Institution (FFI) |
Any financial institution that is a foreign entity, other than a financial institution organized under the laws of a possession of the United States (generally referred to as a U.S. territory). See Regulations Section 1.1471.5(d) for greater detail. |
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| Element | Description |
|---|---|
| Foreign Person | A person who is a nonresident alien individual, a foreign corporation, a foreign partnership, a foreign trust, a foreign estate, and any other person who is not a U.S. person. The term also includes a foreign branch or office of a U.S. financial institution or U.S. clearing organization if the foreign branch is a Qualified Intermediary. Generally, a payment to a U.S. branch of a foreign institution is a payment to a foreign person. |
| Global Intermediary Identification Number (GIIN) |
The term GIIN or Global Intermediary Identification Number means the identification number that is assigned to a participating FFI or registered deemed-compliant FFI. The term GIIN or Global Intermediary Identification Number also includes the identification number assigned to a reporting Model 1 FFI and to Direct Reporting Nonfinancial Foreign Entities for purposes of identifying such entity to withholding agents. All GIINs will appear on the IRS FFI list. |
| Gross Income | Gross income includes income from all sources, except certain items expressly excluded by statute. Gross income is the starting point for computing adjusted gross income and taxable income. |
| Individual Taxpayer Identification Number (ITIN) |
A nine-digit number issued by the IRS to individuals who are required to have a U.S. taxpayer identification number for tax purposes but are not eligible to obtain a Social Security Number (SSN). An ITIN may be used for tax purposes only. |
| Information Return | The vehicle for withholding agents to submit required tax information about a recipient to the IRS. For this publication, it is information about a foreign person’s U.S. source income subject to withholding, and the information return is Form 1042-S. |
| Intermediary | A person who acts as a custodian, broker, nominee, or otherwise, as an agent for another person, regardless of whether that other person is the beneficial owner of the amount paid, a flow-through entity, or another intermediary. |
| Issuer | You’re considered an Issuer if you’re going to electronically file information returns for your business, regardless of the number of locations. Examples of an Issuer include Employer, Payer, Lender, Creditor, Broker, Trustee, Educational Institution and Barter Exchange. |
| Nonqualified Intermediary (NQI) |
A foreign intermediary who is not a U.S. person and is not a Qualified Intermediary. |
| Presumption Rules | A set of rules that a withholding agent must follow to determine the status of the recipient of the payment and the applicable withholding and reporting requirement when it cannot reliably associate a payment with valid documentation. Presumption Rules are prescribed under Chapter 3, 4 and 61 of the Internal Revenue Code. |
| Primary Withholding Agent |
If there are multiple withholding agents with respect to a payment, the primary withholding agent is generally the one that withheld amounts on the payment being reported. Under the multiple withholding agent rule, a withholding agent reporting amounts withheld by another withholding agent must use box 8 (Tax withheld by other agents) to report such amounts and must provide the name and EIN of the withholding agent that withheld the tax in boxes 14a and 14b (Primary Withholding Agent’s Name and EIN). SeeInstructions for Form 1042-S. |
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| Element | Description |
|---|---|
| Pro-Rata Basis Reporting |
Pro-rata basis reporting on Form 1042-S generally applies when a withholding agent makes payments to NQIs that used the alternative procedures under Regulations Section 1.4441-1(e)(3)(iv)(D) and failed to properly comply with those procedures. SeeInstructions for Form 1042-S. |
| Qualified Intermediary (QI) |
A qualified Intermediary is a foreign intermediary or eligible entity that is a party to a withholding agreement with the IRS, in which it agrees to comply with the relevant terms of Chapters 3, 4, and 61 of the Internal Revenue Code. For information on a QI withholding agreement, see Revenue Procedure 2022- 43 (or any superseding revenue procedure). |
| Qualified Intermediary Employer Identification Number (QI-EIN) |
A nine-digit number assigned by the IRS to a QI for federal tax reporting purposes. A QI-EIN is only to be used when a QI is acting as a qualified intermediary. |
| Recipient | SeeInstructions for Form 1042-S for the definition of recipient. |
| Replacement File | A replacement file is an information return file sent by the filer at the request of the IRS because of certain errors encountered while processing the filer’s original submission. |
| Service Bureau | Person or organization with which the withholding agent has a contract to prepare and/ submitting data for a subsidiary is not considered a service bureau. |
| Social Security Number (SSN) |
A nine-digit number assigned by the Social Security Administration to an individual for wage and tax reporting purposes. |
| Special Character | Any character that is not numeric; an alpha or a blank. |
| Taxpayer Identification Number (TIN) |
Refers to either an Employer Identification Number (EIN), Social Security Number (SSN), Individual Taxpayer Identification Number (ITIN), Qualified Intermediary Employer Identification Number (QI-EIN), or a Withholding Foreign Partnership Employer Identification Number (WP-EIN), and Withholding Foreign Trust Employer Identification Number (WT-EIN). |
| Tax Year | The year in which payments were made by a withholding agent to a recipient. |
| Transmitter | You’re considered a Transmitter ifyou’re going to electronically file information returns for other businesses. You may also file information returns for your business, regardless of the number of locations. |
| Transmitter Control Code (TCC) |
A five-character alphanumeric code assigned by the IRS to the transmitter prior to electronically filing. This number is inserted in the record and must be present in all files submitted electronically through the FIRE system. An application must be filed with the IRS to receive this number. Transmitter Control Codes assigned to 1042-S filers will always begin with “22”. |
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| Element | Description |
|---|---|
| Unique Form Identifier | Withholding agents are required to assign a unique identifying number to each Form 1042-S they file. This identifying number is used, for example, to identify which information return is being corrected or amended when multiple information returns are filed by a withholding agent with respect to the same recipient. The unique identifying number cannot be the recipient's U.S. or foreign TIN. The unique identifying number must be numeric, and zeros may not be used for all 10-digits (example: 0000000000). The length of a given identifying number must be exactly 10-digits. The identifying number must be unique to each original Form 1042.S filed for the current year. The identifying number can be used on a new original form in a subsequent year. |
| Unknown Recipient | For this publication, an unknown recipient is a recipient for whom no documentation has been received by a withholding agent or intermediary, or for which documentation received cannot be reliably associated with the recipient, and that is not reported in a pool of payees or account holders provided by a QI/ of payees or account holders provided by an intermediary or flow-through entity for Chapter 4 purposes (i.e., a Chapter 4 Withholding Rate Pool). This includes incomplete documentation. An unknown recipient is always subject to withholding at the maximum applicable rate on payments received of amounts subject to Chapter 3 withholding or withholdable payments. No reduction of or exemption from tax may be applied under any circumstances. |
| Vendor | Vendors include service bureaus that produce information return files for withholding agents. Vendors also include companies that provide software for those who wish to produce their own electronic files. |
| Withholding Agent | Any person, U.S. or foreign, who has control, receipt, or custody of an amount subject to withholding under Chapters 3 or 4 or who can disburse or make payments of an amount subject to withholding. The withholding agent may be an individual, corporation, partnership, trust, association, or any other entity. The term withholding agent also includes, but is not limited to, a qualified intermediary, a nonqualified intermediary, a withholding foreign partnership, a withholding foreign trust, a flow-through entity, a U.S. branch of a foreign insurance company, or foreign bank or territory financial institution that is treated as a U.S. person. A person may be a withholding agent under U.S. law even if there is no requirement to withhold from a payment or even if another person has already withheld the required amount from a payment. |
| Withholding Foreign Partnership (WP) or Withholding Foreign Trust (WT) |
A foreign partnership or trust that has entered into a Withholding Foreign Partnership agreement or Withholding Foreign Trust agreement with the IRS in which it agrees to assume primary withholding responsibility for all payments that are made to it for its partners, beneficiaries, or owners for Chapter 3 and 4 purposes. |
| Withholdable Payments |
A withholdable payment is generally any payment of U.S. source FDAP income, subject to certain exceptions. For exceptions and additional information, see Pub. 515 and Regulations section 1.1473-1(a). |
| Withholding Rate Pool | See Regulations Section 1.1441-1(c)(44) for definition of Chapter 3 Withholding Rate Pool. See Regulations Section 1.1471-1(b)(20) for definition of Chapter 4 Withholding Rate Pool. |
See Regulations Sections 1.1441-1(c) and 1.1471–1(b) for a comprehensive list of Chapter 3 and 4 terms and definitions.
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