Skip to content

Withholding of Tax on Nonresident Aliens and Foreign Entities›Notice 2018-29, 2018-16 I.R.B. 495, available at›How To Get Tax Help

The Taxpayer Advocate Service (TAS) Is Here To Help You

2026 Publ 515 (PDF) · 2026-10-03 edition · updated 2026-10-04 · United States

What Is the Taxpayer Advocate Service?

The Taxpayer Advocate Service (TAS) is an independent organization within the Internal Revenue Service (IRS). TAS helps taxpayers resolve problems with the IRS,

82 Publication 515 (2026)

makes administrative and legislative recommendations to prevent or correct the problems, and protects taxpayer rights. We work to ensure that every taxpayer is treated fairly and that you know and understand your rights under the Taxpayer Bill of Rights. We are Your Voice at the IRS.

How Can TAS Help Me?

TAS can help you resolve problems that you haven’t been able to resolve with the IRS on your own. Always try to resolve your problem with the IRS first, but if you can’t, then come to TAS. Our services are free .

  • TAS helps all taxpayers (and their representatives), including individuals, businesses, and exempt organizations. You may be eligible for TAS help if your IRS problem is causing financial difficulty, if you’ve tried and been unable to resolve your issue with the IRS, or if you believe an IRS system, process, or procedure just isn’t working as it should.

  • To get help any time with general tax topics, visit www.TaxpayerAdvocate.IRS.gov . The site can help

you with common tax issues and situations, such as what to do if you make a mistake on your return or if you get a notice from the IRS.

  • TAS works to resolve large-scale (systemic) problems that affect many taxpayers. You can report systemic issues at www.IRS.gov/SAMS . (Be sure not to include any personal identifiable information.)

How Do I Contact TAS?

TAS has offices in every state, the District of Columbia, and Puerto Rico. To find your local advocate’s number:

What Are My Rights as a Taxpayer?

The Taxpayer Bill of Rights describes ten basic rights that all taxpayers have when dealing with the IRS. Go to www.TaxpayerAdvocate.IRS.gov/Taxpayer-Rights for more information about the rights, what they mean to you, and how they apply to specific situations you may encounter with the IRS. TAS strives to protect taxpayer rights and ensure the IRS is administering the tax law in a fair and equitable way.

Publication 515 (2026) 83

To help us develop a more useful index, please let us know if you have ideas for index entries. Index See “Comments and Suggestions” in the “Introduction” for the ways you can reach us.

Foreign :

10% owners 42 501(c) organizations 58 80/20 company 44

D Deemed-compliant FFI 78 Dependent personal services 53

A Acceptance agent 59 Accounts, offshore 15 Alien :

Defined 12 Illegal 50 Nonresident alien 12 Resident alien 12 Alimony 47 American Samoa 12 Amount to withhold 4

Defined 53 Exempt from withholding 53 Depositing taxes :

(FFI) 78 Foreign person 12 Form :

How to 60 When to 60 Deposits 43 Determining the amount to

501(c) organizations 58 Bank 10, 39 Charitable organizations 13 Corporations 12 Governments 58 Insurance company 10, 39 Intermediary, payee 9 Organizations and associations 13 Partner 64 Partnerships, payee 7 Private foundation 13, 58 Status 28 Trusts, payee 8 Foreign financial institution

Determining the 69 Annuities 47 Artists and athletes :

Earnings of 56 Special events and promotions 56 Assistance ( See Tax help) Awards 49

withhold 69 Disregarded entities 6 Dividend equivalent payments 46 Dividend Equivalents 46 Dividends :

Direct dividend rate 45 Domestic corporation 44 Foreign corporations 45 In general 44 Documentary evidence 16, 29, 31 Documentation 13-34

For chapter 3 13 For chapter 4 13 From foreign beneficial owners and

B Backup withholding 5 Banks, interest received by 42 Beneficial owner 15 Beneficiary of foreign trust 25 Bonds sold between interest

dates 44 Branch profits tax 45

U.S. payees 13 From foreign intermediaries and

foreign flow-through entities 17 Presumptions in the absence of 34

1042 5, 23, 25, 62 1042-S 5, 23, 25, 62 1099 5 1099-S 75 7004 63 8233 50 8288 75 8288-A 75 8288-B 76 8288-C 71 8804 65 8805 66 8813 66 8833 15 8966 5 940 53 941 53 972 45 SS-4 59 W-2 53 W-4 48, 50, 53 W-7 59 W-8 series 15 W-8BEN 15, 16 W-8BEN-E 17 W-8ECI 16, 17 W-8EXP 17 W-8IMY 17 W-9 14, 59 Forms for paying and reporting

C Canada 54, 62 Capital gains 46 Central withholding agreements 56 Chapter 3 withholding 3-13

E Effectively connected income :

Defined 38 Foreign partners 64 Partnerships 5 EFTPS 61 Electronic deposit rules 61 Employees 36, 52 Employer 52 Exceptions to withholding on

transfers of non-PTP interests 68 Exempt beneficial owner 78

Income subject to 34 Payees 7 Persons subject to 6 Chapter 4 withholding 4-13

Payees 7 Persons subject to 6 Withholding rate pool 78 Withholding statement 18 Charitable organizations 13 Commonwealth of the Northern

Mariana Islands (CNMI) 12 Consent dividends 45 Contingent interest 42 Controlled foreign corporations :

F FATCA report 5 Federal unemployment tax 53 Fellowship grants 48 Fellowships 36 Financial institution (FI) 78 Financial institutions 10 FIRPTA withholding 6, 72 Fiscally transparent entity 8 Fixed or determinable annual or

periodic income 37 Flow-through entities 7

G Gambling winnings 56 Global intermediary identification

number (GIIN) 31, 60 Graduated rates 55

section 1446(f)(1) withholding 70 FUTA 53

Interest paid to 42 Covenant not to compete 38 Crew members 36

84 Publication 515 (2026)

Graduated withholding 51 Grants 36, 48, 49 Green card test 12 Guam 12

Nonwage pay 52 Notional principal contract

income 39

O Obligations :

Not in registered form 41 Registered 41 Offshore accounts 15 Original issue discount 40 Overwithholding, adjustment for 61

I Identification number, taxpayer 59,

42 Earnings as an artist or athlete—no central withholding agreement 56 43 Earnings as an artist or athlete—central withholding agreement 56 Independent personal services :

Defined 50 Exempt from withholding 50 Indirect account holders 31 Installment payment 38, 65 Insurance proceeds 38 Interest :

66 Income :

Fixed or determinable annual or

periodical 37 Interest 39 Notional principal contract 39 Other than effectively connected 39 Pensions 37 Personal service 35 Source of 35 Transportation 57 Income code :

P Participating FFI 18, 78 Partner, foreign 64, 66 Partnerships :

foreign partners 64 Foreign payee 7 Publicly traded 66 Withholding foreign 11, 23 Passive NFFE 79 Pay for personal services :

Effectively connected income of

01 Interest paid by U.S. obligors—general 39 02 Interest paid on real property mortgages 42 03 Interest paid to controlling foreign corporations 42 04 Interest paid by foreign corporations 42 06 Dividends paid by U.S. corporations—general 44 07 Dividends qualifying for direct dividend rate 45 08 Dividends paid by foreign corporations 45 09 Capital gains 46 10 Industrial royalties 46 11 Motion picture or television copyright royalties 47 12 Other royalties (for example, copyright, software, broadcasting, endorsement payments) 47 14 Real property income and natural resources royalties 47 15 Pensions, annuities, alimony 47 16 Scholarship or fellowship grants 48 17 Compensation for independent personal services 50 18 Compensation for dependent personal services 53 19 Compensation for teaching 55 20 Compensation during studying and training 55 23 Other Income 57 24 Qualified investment entity (QIE) distributions of capital gains 44 27 Publicly traded partnership distributions subject to IRC section 1446(a) 66 28 Gambling winnings 56 29 Deposit Interest 43 30 Original issue discount (OID) 40 41 Guarantee of indebtedness 57

Contingent 42 Controlled foreign corporations 42 Deposits 43 Foreign business arrangements 43 Foreign corporations 42 Income 39 Portfolio 40, 42 Real property mortgages 42 Intermediary :

resident 12 Who becomes a resident alien 49

Foreign 9 Nonqualified 10 Qualified 9, 10, 18 International organizations 58 IRS Direct Pay 61 ITIN 59

K Knowledge, standards of 27

L Liability of withholding agent 4

M Marketable securities 15 Mexico 54 Model 1 IGA 78 Model 2 IGA 78 Mortgages 42 Multi-level marketing 36

Charitable organizations 13 Fiscally transparent entity 8 Foreign flow-through entities 17 Foreign intermediaries 17 Foreign partnerships 7 Foreign trusts 8 Identifying 6 Nonqualified intermediary 10 Organizations and associations 13 Private foundations 13 Qualified intermediary 10 U.S branches of foreign persons 13 Penalties :

Artists and athletes 56 Dependent personal services 53 Employees 51 Exempt from withholding 50 Independent personal services 50 Salaries and wages 51 Scholarship or fellowship

recipient 48 Studying 55 Teaching 55 Training 55 Payee :

N Non-financial foreign entity

(NFFE) 78 Non-registered obligations 41 Nonparticipating FFI 78 Nonqualified intermediary 21

Alternative withholding

procedure 22 Chapter 4 withholding rate pool 22 Defined 10 For chapter 3 purposes 21 For chapter 4 purposes 21 Pooled withholding 22 Withholding statement 21 Nonresident alien :

Deposit 61 Form 1042 63 Form 8804 66 Form 8805 66 Trust fund recovery 53 Pensions 37, 47 Per diem 49 Personal service income 35 Pooled withholding information 22 Portfolio interest 40, 42 Presumption rules :

Defined 12 Married to U.S. citizen or

Corporation 34 Individual 34

Publication 515 (2026) 85

Partnership 34 Trust 34 Private foundation, foreign 13 Prizes 49 Publications ( See Tax help) Puerto Rico 12, 54

Short-term obligation 44 Source of income 35 Standards of knowledge :

For chapter 3 27 For chapter 4 31 Substantial presence test 12

W Wages :

Q QI agreement 10 Qualified derivatives dealer

Paid to employees 51 Pay that is not 52 When to withhold 4 Withhold, amount to 4 Withhold, when to 4 Withholdable payment 4, 6, 79 Withholding :

(QDD) 79 Qualified intermediary :

Agency option 20 Collective refund procedures 21 Defined 18 Joint account treatment 20 Payee 10 Reporting on Form 1042-S 21 Responsibilities and

T Tax help 79 Tax treaties ( See Treaties) Tax-exempt entities 58 Taxpayer identification number

Agreements 50, 56 Certificate 27, 31 Chapter 3 3 Chapter 4 4 In general 3 On specific income 38 Rate pool 22, 78 Real property 72 Reporting and paying 65 Withholding agent 3

grants 48 Students 55 Withholding agreements 50, 56 Withholding foreign partnership

documentation 19 Qualified investment entity (QIE) :

(TIN) 59, 66 Exceptions 59 Teachers 55 Ten-percent owners 42 Territorial limits 36 Territory financial institution 79 Transfers of partnership interests

subject to withholding under sections 1445(e)(5) and 1446(f) (1) 70 Transportation income 57 Travel expenses 51 Treaties :

Claiming benefits for chapter 3 15 Dependent personal services 54 Entertainers and athletes 56 Gains 46 Independent personal services 51 Rate tables 79 Students 49, 55 Teaching 55 Trainees 55 Trust Territory of the Pacific

Liability 4 Returns required 61 Tax deposit requirements 60 Withholding exemptions and

Distributions paid by 73 Dividends paid by 44

R Racing purses 38 Real property interest :

Disposition of 72 Withholding certificates 75 Withholding obligation 6 Reason to know 27 Recalcitrant account holder 79 Registered deemed-compliant

FFI 18, 79 Registered obligations 41 Reporting and paying the tax 65 Reporting Model 1 FFI 79 Reporting Model 2 FFI 79 Researchers 55 Resident alien, defined 12 Returns required 61 Royalties 46, 47 Ryukyu Islands 44

reductions : Dependent personal services 53 Exemption 38 Final payment exemption 50 Foreign governments 58 International organizations 58 Real property interest 75 Researchers 55 Scholarships and fellowship

Islands 44 Trusts :

Foreign payee 8 Withholding foreign 11, 25

U U.S. agent of foreign person 6 U.S. branch :

(WP) : Agency option 24 Collective refund procedures 23 Joint account treatment 23 Not acting as WP 25 Withholding foreign trust (WT) :

Agency option 26 Collective refund procedures 25 Joint account treatment 26 Not acting as WT 27 Reporting U.S. beneficiaries 25 Responsibilities of 25 Withholding on transfers of

S Salaries 51 Saving clause 49 Scholarships 36, 48 Section 1446(f) Withholding 67 Section 1446(f)(1) withholding 70 Sections 1446(a) and (f)

Foreign bank 10, 39 Foreign insurance company 10, 39 Foreign person 13 U.S. real property interest ( See Real

property interest) U.S. savings bonds 44 U.S. territorial limits 36 U.S. territory, resident of 12 U.S. Virgin Islands (USVI) 12 Unexpected payment 59

non-PTP interests, exceptions to 68 Withholding under sections

1445(e)(5) and 1446(f)(1) 70

withholding 14 Securities 38 Securities, marketable 15 Services performed outside the

U.S. 53

86 Publication 515 (2026)

Get a plain-English answer with a citation back to this text.

Ask AI about this code
▸Contents — 2026 Publ 515 (PDF)

GoCodebook provides public access, search, citation, multilingual explanation, and practical interpretation of legally adopted building regulations. It is not a substitute for the official ICC or California code publications.