DC is preparing to distribute cash dividends to itsshareholders. Must it w/h tax under sec 1441 from thedividends?
(a) Shareholder A is a US citizen who resides in France. Onlyher French address appears in the corporation's books.
see reg 1.1441-1(b)(1), (b)(2)(i), (b)(2)(vii), (b)(3)(i),(b)(3)(iii).
(b) Shares of Shareholder B, a citizen and resident of France,are held by a New York broker and are registered in the name of anominee corporation of the broker.
For the w/h obligation generally, see reg 1.1441-1(b)(1),(b)(2)(i), (b)(2)(ii). For w/h at treaty rates, see reg.1.1441-1(e)(1)(ii)(A)(1), (e)(2), -6(a), (b)(1), (b)(3), (c)(1),(c)(2).
