Customer Tax Guide - U.S.A.
Debt Securities
Equities
Withholding Tax
Capital Gains Tax
Stamp Duty
March 2013
Customer Tax Guide - U.S.A.
March 2013 edition
Document No. US6065
This document is the property of Clearstream Banking société anonyme (“Clearstream Banking”). No part of this
document may be reproduced or transmitted in any form or by any means, electronic or mechanical, including
photocopying and recording, for any purpose without the express written consent of Clearstream Banking. Information in
this document is subject to change without notice and does not represent a commitment on the part of Clearstream
Banking, or any other entity belonging to Clearstream International.
© Copyright Clearstream International (2012). All rights reserved.
Clearstream Banking société anonyme is organised with limited liability in the Grand Duchy of Luxembourg,
RC Luxembourg B 9248.
Registered address: Clearstream Banking SA, 42 Avenue JF Kennedy, L-1855 Luxembourg.
United States of America
Overview
2
Types of accounts for different recipients
9
Debt securities
12
Equities
35
Reporting of withholding tax and backup
withholding tax
57
Appendices
Clearstream Banking
Customer Tax Guide - United States of America
A-1
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U.S.A. - Overview
Overview
Debt securities
1. Interest and Long-term Original Issue Discount (OID)1 issued after 31 December 2000

Domestic
Treasury
Securities a
Domestic Fedwireeligible Federal Agency
and Federally Sponsored
Agency Securities b
Domestic
DTCC MBSeligible
Securities c
Global Bonds d
and Corporate
Bonds e
Standard Rate of
Withholding Tax Backup
Withholding Tax f

30% - 28%
30% - 28%
30% - 28%
30% - 28%
Relief at
Source
available
(see page 21)

Yes
Yes
Yes
Yes
Security
Type
- Qualified Intermediaries (QIs)
- Non-Qualified Intermediaries (NQIs)
- Foreign account holders g
- U.S. persons
Eligible
Recipients

Reclaim via
CBL available
(see page 33)

Eligible
Recipients

Capital Gains
Tax at Source

No
No
No
No
Stamp Duty
at Source

No
No
No
No
Yes
Yes
Yes
Yes
Qualified Intermediaries (QIs)
a. Including: Bills; Notes; Bonds; CUBEs (Coupons Under Book-Entry); STRIPs (Securities in which there is Separate Trading of
Registered Interest and Principal); TCAL (U.S. Treasury Callable Corpus).
b. Including: FHLB (Federal Home Loan Bank securities); FHLMC (Federal Home Loan Mortgage Corporation securities); FNMA
(Federal National Mortgage Association securities); SLMA (Student Loan Marketing Association securities).
c. The MBS (Mortgage Backed Securities) Clearing Corporation has been incorporated into DTCC (Depository Trust Clearing
Corporation).
d. Debt securities issued by U.S. issuers (instrument issued in permanent global form in two and sometimes three markets; enables a
bond issuer to attract investors for the same issues from both the euro market and the domestic market) income on which is
subject to U.S. withholding tax.
e. Including Commercial Paper.
f. Withholding tax and backup withholding tax apply to interest (in the case of current payments) or to OID (in the case of redemptions).
g. Including:
- Non-U.S. beneficial owners resident of a DTT country eligible for relief at source for debt securities issued prior to July 1984;
- Non-U.S. beneficial owners eligible for portfolio interest exemption for debt securities issued after July 1984, only if they own less
than 10% of the issue and are not a controlled foreign corporation in relation to the issuer;
- Foreign governments and international organisations recognised as tax exempt under U.S. law;
- Non-U.S. beneficial owners having effectively connected income related to a trade or business conducted in the U.S.A.
Qualified Intermediary (QI) status of Clearstream Banking
Clearstream Banking as a QI assumes both primary NRA withholding responsibility and backup
withholding and 1099 reporting responsibility.
1. Paid at redemption on registered debt securities issued after 31 December 2000 with initial maturity of more than 183 days.
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Customer Tax Guide - United States of America
U.S.A. - Overview
Withholding tax
The standard rate of U.S. withholding tax on interest and long-term OID is 30%. An exemption at source
from withholding tax based on U.S. domestic law is available on:
• Interest of debt securities paid to:
− Foreign governments and international organisations recognised as tax exempt;
− Foreign person whose income is effectively connected with a trade or business conducted in
the U.S.A.;
− U.S. persons;
• OID on debt securities issued after 31 December 2000 to all eligible recipients;
• Interest on debt securities in registered form (except the U.S. Foreign Targeted Bonds in
registered form) issued after July 1984 paid to all eligible recipients.
Relief at source is available for interest payments on debt securities issued prior to July 1984 if the
recipient qualifies for the benefit of a reduced rate of withholding tax in accordance with a Double
Taxation Treaty (DTT) between its country of residence and the U.S.A., subject to limitation of benefits
(LOB - see “Limitation of Benefits (LOB)” on page 18).
Relief at source or exemption at source is available only if the appropriate documentation is submitted
to Clearstream Banking.
A reclaim of withholding tax is available through Clearstream Banking under certain conditions (see
“Reclaiming withholding tax from Clearstream Banking” on page 33).
Claim for refund of withholding tax from the IRS is not available through Clearstream Banking.
Backup Withholding tax
The standard rate of U.S. backup withholding tax on interest and OID paid on debt securities issued
after 31 December 2000 is currently 28% for undocumented recipients.
An exemption at source from backup withholding tax is available to eligible recipient on interest and OID
based on U.S. domestic law.
Exemption at source is available only if the appropriate documentation is submitted to Clearstream
Banking.
Claim for refund of backup withholding tax from the IRS is not available through Clearstream Banking.
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U.S.A. - Overview
2. Interest and Long-term Original Issue Discount (OID)1 issued prior to 1 January 2001

Yankee
Bonds a
Municipal
Bonds b
Foreign
Targeted
Bearer Bonds c
OID issued
before
1 January 2001

0%
0%
0%
0%

-
-
-
-

-
-
-
-

-
-
-
-

-
-
-
-
Capital Gains
Tax at Source

No
No
No
No
Stamp Duty
at Source

No
No
No
No
Security
Type
Standard Rate of
Withholding Taxd
Relief at
Source
available
(see page 21)
Eligible
Recipients
Reclaim
available
(see page 33)
Eligible
Recipients
a. Security issued in the U.S.A. by a non-U.S. borrower and underwritten by a predominantly American syndicate, always
managed by a U.S. investment bank and mainly placed in the U.S.A.
b. Tax-exempt securities issued in the U.S.A. by local governments.
c. A bearer obligation is foreign-targeted if:
There are arrangements to ensure that the obligation will be sold, or re-sold in connection with the original issue, only
to a person who is not a U.S. person; and
Interest on the obligation is payable outside the U.S.A. and its possessions; and
The face of the obligation contains a statement that any U.S. person who holds the obligation will be subject to limits
under the U.S. income tax laws.
d. Withholding tax applies to interest in the case of current payments.
Withholding tax
The standard rate of U.S. withholding tax on interest and OID is 30%. No withholding tax is deducted
from interest payments on the Yankee Bonds and Municipal Bonds held in Clearstream Banking or
long-term OID on debt securities with maturity more than 183 days and issued prior to 1 January 2001.
An exemption at source from withholding tax is available to eligible recipient on interest payments of
U.S. Foreign Targeted Bonds in registered form, based on U.S. domestic law.
Exemption at source is available only if the appropriate documentation is submitted to Clearstream
Banking. The procedure applicable to U.S. Foreign Targeted Bonds in registered form is published
annually in a Clearstream Banking announcement.
A reclaim of withholding tax is available through Clearstream Banking under certain conditions (see
“Reclaiming withholding tax from Clearstream Banking” on page 33).
Claim for refund of withholding tax from the IRS is not available through Clearstream Banking.
Backup Withholding tax
No backup withholding tax is deducted on long-term OID paid on debt securities issued prior to
1 January 2001, or interest paid on Yankee Bonds, Municipal Bonds and Foreign Targeted Bearer Bonds.
1. Paid at redemption on registered debt securities issued before 1 January 2001 with initial maturity of more than 183 days.
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U.S.A. - Overview
3. Short-term Original Issue Discount (OID)1 and interest on Certificates of Deposit
Domestic Fedwireeligible Federal
Agency and Federally
Sponsored Agency
Securities b
Domestic
DTCC MBSeligible
Securities c
Global Bonds d,
Corporate
Bonds e and
Certificates of
Deposit
Security
Type

Domestic
Treasury
Securities a
Standard Rate of
Backup
Withholding Tax f

28%
28%
28%
28%
Relief at
Source
available
(see page 21)

Yes
Yes
Yes
Yes
Eligibility

Reclaim via
CBL available
(see page 33)

No
No
No
No
Eligibility

-
-
-
-
Capital Gains
Tax at Source

No
No
No
No
Stamp Duty
at Source

No
No
No
No
Documented recipients only
a. Including: Bills; Notes; Bonds; CUBEs (Coupons Under Book-Entry); STRIPs (Securities in which there is Separate Trading of
Registered Interest and Principal); TCAL (U.S. Treasury Callable Corpus).
b. Including: FHLB (Federal Home Loan Bank securities); FHLMC (Federal Home Loan Mortgage Corporation securities); FNMA
(Federal National Mortgage Association securities); SLMA (Student Loan Marketing Association securities).
c. The MBS (Mortgage Backed Securities) Clearing Corporation has been incorporated into DTCC (Depository Trust Clearing
Corporation).
d. Including the Global Depository Receipts (GDRs) representing securities issued by U.S. issuers (instrument issued in permanent
global form in two and sometimes three markets; enables a bond issuer to attract investors for the same issues from both the euro
market and the domestic markets) income on which is subject to U.S. withholding tax.
e. Including Commercial Paper.
f. Backup withholding tax applies to short-term OID in the case of redemption, only if Presumption Rules are applied.
Withholding tax
Short-term OID and interest on Certificates of Deposit are not subject to withholding tax.
Backup Withholding tax
The standard rate of U.S. backup withholding tax on interest on Certificates of Deposit and short-term
OID is currently 28% for undocumented recipients.
An exemption at source from backup withholding tax is available to all eligible recipients on short-term
OID and interest on Certificates of Deposit, based on U.S. domestic law.
Exemption at source is available only if the appropriate documentation is submitted to Clearstream
Banking.
Claim to refund of backup withholding tax from the IRS is not available through Clearstream Banking.
1. Paid at redemption on registered debt securities with an initial maturity of 183 days or less.
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U.S.A. - Overview
Capital gains tax
There is no capital gains tax withheld through Clearstream Banking on securities held in Clearstream
Banking. Capital gains tax may however be payable on specific gains. Clearstream Banking does not
assist in this regard. Please consult your tax advisor for further information.
Stamp duty
There is no stamp duty withheld through Clearstream Banking on securities held in Clearstream
Banking. Stamp duty may however be payable on specific transactions. Clearstream Banking does not
assist in this regard. Please consult your tax advisor for further information.
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U.S.A. - Overview
Equities

DTCC - eligible
Equities and
Equity
Products
International
Depository
Receipts
(IDRs) a
Global
Depository
Receipts
(GDRs) b
American
Depository
Receipts
(ADRs) c
Standard Rate of
Withholding Tax Backup
Withholding Taxd

30% - 28%
30% - 28%
30% - 28%
0%
Relief at
Source
available
(see page 44)

Yes
Yes
Yes
-
Security
Type
- Qualified Intermediaries (QIs)
- Non-Qualified Intermediaries (NQIs)
- Foreign account holders e
- U.S. persons
Eligible
Recipients

Reclaim
available
(see page 56)

Eligible
Recipients

Capital Gains
Tax at Source

No
No
No
No
Stamp Duty
at Source

No
No
No
No
Yes
Yes
Yes
Qualified Intermediaries (QIs)
-
-
a. Representing securities issued by non-U.S. issuers on behalf of U.S. companies (a receipt for shares issued and traded
in the euro market in bearer form) income on which is subject to U.S. withholding tax.
b. Representing securities issued by U.S. issuers (instrument issued in permanent global form in two and sometimes
three markets; enables a issuer to attract investors for the same issues from both the euro market and the domestic
markets) income on which is subject to U.S. withholding tax.
c. Representing a depository receipt issued against foreign securities by an American bank that holds those securities,
income on which are not subject to U.S. withholding tax.
d. Withholding tax and backup withholding tax apply to dividends in the case of current payments.
e. Including also:
- The effectively connected income related to a trade or business conducted in the U.S.A. by the beneficial owner;
- The foreign governments and international organisations recognised as tax exempt under U.S. law.
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U.S.A. - Overview
Withholding tax
The standard rate of U.S. withholding tax on dividends is 30%. No withholding tax is deducted from
dividend payments on the American Depository Receipts held in Clearstream Banking
An exemption at source from withholding tax is available to eligible recipient on certain dividend
payments of equities, based on U.S. domestic law.
Relief at source is available for certain dividend payments on equities, if the recipient qualifies for the
benefit of a reduced rate of withholding tax in accordance with a Double Taxation Treaty (DTT) between
its country of residence and U.S.A., subject to limitation of benefits (LOB - See “Limitation of Benefits
(LOB)” on page 40).
Relief at source or exemption at source on dividend payments is available only if the appropriate
documentation is submitted to Clearstream Banking.
A reclaim of withholding tax is available through Clearstream Banking under certain conditions (see
“Reclaiming withholding tax from Clearstream Banking” on page 56).
Claim for refund of withholding tax from the IRS is not available through Clearstream Banking.
Backup Withholding tax
The standard rate of U.S. backup withholding tax on dividends is currently 28% for undocumented
recipients.
An exemption at source from backup withholding tax is available to eligible recipients on certain
dividend payments of equities, based on U.S. domestic law.
Exemption at source is available only if the appropriate documentation is submitted to Clearstream
Banking.
Claim for refund of backup withholding tax from the IRS is not available through Clearstream Banking.
Capital gains tax
There is no capital gains tax withheld through Clearstream Banking on securities held in Clearstream
Banking. Certain capital gains distribution may however be reported. Clearstream Banking does not
assist in this regard. Please consult your tax advisor for further information.
Stamp duty
There is no stamp duty withheld through Clearstream Banking on securities held in Clearstream
Banking. Stamp duty may however be payable on specific transactions. Clearstream Banking does not
assist in this regard. Please consult your tax advisor for further information.
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Customer Tax Guide - United States of America
U.S.A. - Types of accounts for different recipients
Types of accounts for different recipients
The different types of accounts depend on the recipients' status and are as follows:
Foreign account holders
A Clearstream Banking customer that is a foreign account holder is required to hold U.S. securities that he
beneficially owns in an account separate from the account(s) in which he holds securities for third parties.
U.S. persons
A Clearstream Banking customer that is a U.S. person may hold all U.S. securities in an omnibus account.
Qualified Intermediaries (QIs)
There are different types of accounts available in Clearstream Banking depending on whether the QI
acts and assumes primary withholding responsibility and/or primary backup withholding and Form
1099 reporting responsibility.
The documentation required from underlying holders varies for different types of accounts, as follows:
QI type A
The QI has assumed primary NRA withholding responsibility and backup withholding and 1099
reporting responsibility with respect to all U.S. securities held in the account.
All securities can be held in the same account (omnibus account) with Clearstream Banking and no
Allocation Information is required. For each account with Clearstream Banking for which the customer
is acting in this capacity, the customer must provide:
• A form W-8IMY confirming the customer is a QI with primary NRA withholding responsibility and
backup withholding and 1099 reporting responsibility;
• Qualified Intermediary Employee Identification Number (QI EIN) issued by the IRS; and
• A Withholding Statement confirming the customer's responsibilities.
QI type B
The QI has assumed primary NRA withholding responsibility and has not assumed backup withholding
and 1099 reporting responsibility with respect to all U.S. securities held in the account.
For each account with Clearstream Banking for which the customer is acting in this capacity, the
customer must provide:
• A form W-8IMY confirming the customer is a QI with primary NRA withholding responsibility;
• Qualified Intermediary Employee Identification Number (QI EIN) issued by the IRS; and
• A Withholding Statement associating payments with valid documentation and undertaking to
communicate allocation information for reporting purposes to Clearstream Banking, for those
accounts for which this information is required.
Account type for non-U.S. and U.S. exempt persons
All securities can be held in an omnibus account with Clearstream Banking. No Allocation Information
and no further documentation are required.
Account types for U.S. non-exempt persons
The QI must either hold the securities in:
• An omnibus account for U.S. non-exempt person and to provide:
− A form W-9 from each recipient; and
− An Allocation Information per payment and by recipient.
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U.S.A. - Types of accounts for different recipients
or in:
• A segregated account per U.S. non-exempt person and to provide:
− A form W-9 from each recipient.
No further Allocation Information is required.
QI type C
The QI has not assumed primary NRA withholding responsibility and has not assumed backup
withholding and 1099 reporting responsibility with respect to all U.S. securities held in the account.
For each account with Clearstream Banking for which the customer is acting in this capacity, the
customer must provide:
• A form W-8IMY confirming the customer is a QI without primary NRA withholding responsibility;
• Qualified Intermediary Employee Identification Number (QI EIN) issued by the IRS; and
• A Withholding Statement associating payments with valid documentation and confirming which
rate(s) of withholding tax are to be applied to payments or undertaking to communicate
withholding rates and/or allocation information for reporting purposes to Clearstream Banking,
for those accounts for which this information is required.
Account types for non-U.S. and U.S. exempt persons
The QI must hold the securities either in:
• An omnibus account for non-U.S. and U.S. exempt, in which case the QI must provide:
− An Allocation Information per payment and by recipient;
or in:
• Segregated accounts per withholding pool, as follows:
− Per interest/dividend DTT rate on debt securities/equities;
− For documented non-U.S. beneficial owners for whom exception is claimed on interest and
long-term OID;
− For documented non-U.S. beneficial owners for whom no tax relief is claimed on interest and
long-term OID/dividends;
− For undocumented beneficial owners not presumed to be U.S. non-exempt persons;
− For all U.S. exempt persons, U.S. branches with effectively connected income, non-U.S. tax
exempt foreign governments, international organisations and charities.
Account types for U.S. non-exempt persons
The QI must hold the securities either in:
• An omnibus account for U.S. non-exempt person, in which case the QI must provide:
− A form W-9 from each recipient; and
− An Allocation Information per payment and by recipient.
or in:
• A segregated account per U.S. non-exempt person, in which case the QI must provide:
− A form W-9 from each recipient. (No further Allocation Information is required.)
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U.S.A. - Types of accounts for different recipients
Non-Qualified Intermediaries (NQIs) and Flow-Through Entities (FTEs)
In order to obtain relief, customers that remain NQIs are required to hold U.S. securities in separate
(segregated) accounts, and provide the indicated documentation, as follows:
•
Per beneficial owner that is a U.S. non-exempt person:
− A form W-8IMY completed by the customer stating that the customer is an NQI;
− A Withholding Statement for the account concerned; and
− A form W-9 completed by the U.S. non-exempt person.
•
Per U.S. exempt person:
− A form W-8IMY completed by the customer stating that the customer is an NQI;
− A Withholding Statement for the account concerned; and
− A form W-9 completed by the U.S. exempt person.
•
Per beneficial owner that is a non-U.S. person for whom the customer requests tax relief:
− A form W-8IMY completed by the customer stating that the customer is a NQI;
− A Withholding Statement for the account concerned with details of the withholding pool; and
− The appropriate form W-8BEN, W-8EXP, W-8ECI completed by the non-U.S. beneficial owner.
•
Per QI withholding rate and reporting pool for each QI for whom the NQI holds securities:
− A form W-8IMY completed by the customer stating that the customer is an NQI;
− A form W-8IMY completed by the QI; and
− A Withholding Statement for the account concerned with details of the QI withholding pool.
•
Per underlying NQI with a single beneficial owner:
− A form W-8IMY completed by the customer stating that the customer is an NQI;
− A Withholding Statement for the account concerned;
− A form W-8IMY completed by the underlying client stating that the client is an NQI; and
− The appropriate form W-8BEN, W-8EXP, W-8ECI, W-9 completed by the non-U.S. beneficial
owner, U.S. exempt person or U.S. non-exempt person.
Account types for non-U.S. beneficial owners for which no tax relief is requested
The NQI must hold the securities in a segregated account per (documented) beneficial owner, in which
case the NQI must provide:
• A form W-8IMY completed by the customer stating that the customer is an NQI;
• A Withholding Statement for the account concerned; and
• A statement of the beneficial owner's details (as in a W-8BEN) and non-U.S. status.
The summary of the above account types is provided in Appendix 3 on page A-7.
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U.S.A. - Debt securities
Debt securities
Who can obtain relief at source through Clearstream Banking?
Flow 1. Debt securities: Foreign account holders
Is the eligible recipient a
Foreign Account Holder / NRA?
No
The eligible recipient is a U.S. Account Holder
/ U.S. Person (see page 13).
Yes
Is the eligible recipient a Direct Account
Holder, that is, a Beneficial Owner?
No
The eligible recipient is a Qualified
Intermediary (QI) (see page 14) or
a Non-Qualified Intermediary (NQI) / FlowThrough Entity (FTE) (see page 15).
Yes
Correct A. W-8BEN, W-8ECI, W-8EXP (except
W-8IMY); and B. Withholding Statement?
No
Application of Presumption Rules
(see page 16).
Yes
Yes
New contradictory information?
No
Yes
Income from U.S. securities?
Yes
Documentation validity: A. Reason to know; or
B. Actual knowledge?
Yes
No
No withholding
tax impact.
Account holder delivers corrected details
(for example, different WHT rate) to
Clearstream Banking prior to payment?
No
Application of Presumption Rules
(see page 16).
Post-July 1984 U.S. debt securities:
0% - Portfolio interest exception with documentation.
Pre-July 1984 Bonds and other interest income:
0%, if exemption at source; or
DTT rate, if applicable; otherwise, 30%.
1042-S reporting
(see page 58).
Long-term OID issued after 31 December 2000:
At redemption: 0% / reportable
Before redemption: Not taxable / not reportable.
Short-term Original Issue Discount (OID):
At redemption - Not taxable / not reportable.
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U.S.A. - Debt securities
Flow 2. Debt securities: U.S. account holders / U.S. persons
Is the eligible recipient a U.S. Account
Holder / U.S. Person?
No
The eligible recipient is a Foreign Account
Holder / NRA (see page 12).
Yes
Is the eligible recipient
the Direct Account Holder?
No
The eligible recipient is a Qualified
Intermediary (QI) (see page 14) or
a Non-Qualified Intermediary (NQI) / FlowThrough Entity (FTE) (see page 15).
Yes
Is the recipient U.S. non-exempt,
undocumented?
Yes
No
Application of backup withholding tax
and Presumption Rules (see page 16)
prior to 1 Jan 2003. As of 1 Jan 2003,
no U.S. securities can be held for U.S.
undocumented recipients.
No
Is the recipient U.S. non-exempt,
documented but undisclosed
(natural person or per se or
other corporation)?
Yes
Does the recipient have
documentary evidence?
Yes
No
Is the recipient U.S. exempt,
documented and disclosed?
Yes
No
Has the recipient provided:
A. Valid form W9 with the
“Exempt” box checked; and
B. Withholding statement.
Yes
No
Is the recipient U.S. non-exempt,
documented and disclosed
(natural person or per se or
other corporation)?
Yes
Has the recipient provided:
A. Valid form W9; and
B. Withholding statement.
Yes
No
Income from U.S. securities?
No
Yes
No withholding
tax impact.
30% on U.S. debt securities,
long-term OID issued after 1 Jan
2001 and short-term OID.
1099 reporting
(see page 58)
0% on U.S. debt securities,
long-term OID issued after 1 Jan
2001 and short-term OID.
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U.S.A. - Debt securities
Flow 3. Debt securities: Qualified Intermediaries (QIs)
Is the eligible recipient an Intermediary
or a Flow-Through Entity (FTE)?
No
Yes
Is the eligible recipient a Qualified
Intermediary (QI) or a Withholding
Foreign Partnership (WFP)?
No
The eligible recipient is a Foreign Account
Holder / NRA (see page 12)
or a U.S. Account Holder or U.S.
Person (see page 13).
The eligible recipient is a Non-Qualified
Intermediary (NQI) or FTE (see page 15).
Yes
Can Clearstream Banking reliably
associate the payment with:
A. A valid W-8IMY plus Withholding
Statement provided by the QI/WFP; and
B. A withholding rate pool as per the
Withholding Statement?
No
Yes
Application of Presumption Rules
(see page 16).
Income from
U.S. securities?
No
No withholding
tax impact.
Yes
QI A
QI B
All
Omnibus
Account, 0%
1042-S reporting
(see page 58).
Non-U.S. and
U.S. exempt
U.S. non-exempt
Omnibus
Account, 0%
Omnibus Account,
0%, W-9 +
Allocation
Information
1099 reporting
(see page 58).
Segregated
Account, 0%, W-9
QI C
Non-U.S. and
U.S. exempt
Omnibus Account,
30% / 0% or DTT
rate - Allocation
Information
Segregated
Account, 0% or
DTT rate
Segregated
Account, 30%
U.S. non-exempt
Omnibus Account,
0%, W-9 +
Allocation
Information
U.S.
exempt
1099 / 1042-S
reporting
(see page 58).
Documented NonU.S. tax relief;
DTT rate account
No reporting.
Documented NonU.S. - no tax relief
requested;
Undocumented
Non-U.S. no tax
relief
1042-S reporting
(see page 58).
1099 reporting
(see page 58).
Segregated
Account, 0%, W-9
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Flow 4. Debt securities: Non-Qualified Intermediaries (NQIs) or Flow-Through Entities (FTEs)
Is the eligible recipient an Intermediary
or a Flow-Through Entity (FTE)?
No
The eligible recipient is a Foreign Account
Holder / NRA (see page 12)
or a U.S. Account Holder or U.S.
Person (see page 13).
No
The eligible recipient is a Qualified
Intermediary (QI) or a Withholding Foreign
Partnership (WFP) (see page 14).
Yes
Is the eligible recipient a Non-Qualified
Intermediary (NQI) or an FTE?
Yes
A. Has Clearstream Banking received a valid
W-8IMY plus Withholding Statement provided
by the NQI or FTE; and
B. Can Clearstream Banking reliably
associate the payment with valid
documentation provided by account holders
that are not themselves NQI or FTE (W-8BEN,
W-8ECI, W-8EXP, W-8IMY, W-9)?
No
Yes
Application of Presumption Rules
(see page 16).
Income from
U.S. securities?
No
No withholding
tax impact.
Yes
Segregated
Account
Omnibus
Account
U.S. non-exempt
0%, W-9
1099 reporting
(see page 58).
U.S. exempt
0%, W-9
No reporting.
Non-U.S. beneficial
owner, tax relief
0% / DTT rate,
W-8BEN, W-8EXP,
W-8ECI
QI withholding and
reporting pool
Rate per withholding
and reporting pool,
W-8IMY
Non-U.S. beneficial
owner, no tax relief
30% / 0%, W-8BEN
NQI with single
beneficial owner
0% / DTT rate,
W-8IMY, W-8BEN, W8EXP, W-8ECI, W-9
Non-U.S. beneficial
owner, U.S. taxexempt, tax relief
0% / DTT rate,
W-8BEN, W-8EXP,
W-8ECI, W-9,
Allocation
Information
Non-U.S.:
1042-S reporting;
U.S. exempt:
No reporting;
(see page 57).
U.S. non-exempt
0%, W-9,
Allocation
Information
1099 reporting
(see page 57).
Clearstream Banking
Customer Tax Guide - United States of America
1042-S reporting
(see page 58).
Non-U.S.:
1042-S reporting
(see page 58);
U.S. exempt:
No reporting;
U.S. non-exempt:
1099 reporting;
(see page 58).
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Summary of relief available
The standard rate of withholding tax on interest and long-term OID is 30%. The current backup
withholding rate is 28%.
Know Your Customer (KYC) Rules
The KYC Rules refer to the applicable laws, regulations, rules and administrative practices and
procedures, identified in the attachments to the Qualified Intermediary Agreement (QIA), governing the
requirements of the QI to obtain documentation confirming the identify of the QI’s account holders.
Details on the KYC Rules are published on the IRS web site: www.irs.gov.
Presumption Rules
A QI must generally apply the Presumption Rules to determine the status of an account holder if it
cannot reliably associate a payment with valid documentation from that account holder. The QI
agreement provides that an amount subject to withholding tax that is paid outside the U.S.A. is
presumed made to an undocumented foreign account holder.
According to the Presumption Rules, if a payee is a corporation, a withholding agent (such as a QI) shall
not treat the payee as the beneficial owner of the income if the withholding agent knows, or has reason
to know, that the payee is not the beneficial owner. For this purpose a withholding agent has reason to
know that the payee is not the beneficial owner of income if documentary evidence indicates that the
payee is a bank, broker, intermediary, custodian, or other agent, or is treated as such a person under
the U.S. regulations. Even though the QI may not have documentary evidence in this case, interpretation
of U.S. regulations provides that a payer may treat a payee as a financial institution (bank) if the
person's name (including a foreign name such as “Banco” or “Banque”) reasonably indicates that the
payee is a financial institution.
Therefore, if the name of the Clearstream Banking customer reasonably indicates that it is a bank,
Clearstream Banking will treat it as such an entity and will not treat the bank as the beneficial owner of the
income. Without documentation (that is, W-8BEN, W-8EXP or W-8ECI) the bank will, as a result, default to
Non-Qualified Intermediary (NQI) status subject to maximum withholding tax rate of 30% at source.
Foreign exchange
For withholding and reporting purposes, the IRS requires that all information be made in U.S. dollars
(USD). Tax withheld is converted to USD, based on the average weekly foreign exchange rate applicable
at the time of withholding. The foreign exchange conversion is provided by the Treasury department of
Clearstream Banking and is obtained in a manner consistent with the IRS regulations.
Reimbursement of reclaims will be made in USD for the equivalent foreign currency of tax withheld on the
relevant income payment, based upon the foreign exchange conversion rate at the time of withholding.
Debt securities - liability to withholding tax
Debt securities not subject to withholding tax or backup withholding tax
Interest on the following debt securities is not subject to withholding tax or backup withholding tax:
• Yankee Bonds;
• Municipal Bonds;
• Foreign Bearer Bonds;
• Debt securities with OID having a maturity more than 183 days and issued prior to 1 January 2001.
• OID instruments sold between interest payment dates.
The interest paid as part of the purchase price of a bond sold between interest payment dates
and OID paid as part of the purchase price of a bond in a transaction other than the redemption
of such a bond are not subject to Non-Resident Alien (NRA) withholding.
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Debt securities not subject to withholding tax but subject to backup withholding tax
Interest and/or OID on the following debt securities is not subject to withholding tax, but it is subject to
backup withholding tax:
• Certificates of Deposit;
• Short-term OID paid at redemption, on registered debt securities with an initial maturity of 183
days or less.
Debt securities subject to both withholding tax and backup withholding tax
Interest on the following debt securities is subject to withholding tax and to backup withholding tax:
• Domestic Treasury Securities;
• Domestic Fedwire - Eligible Federal Agency and Federally Sponsored Agency Securities;
• Domestic DTCC MBS - Eligible Securities;
• Global Bonds;
• Corporate Bonds;
• Long-term OID paid at redemption, on registered debt securities with a maturity of more than
183 days issued after 31 December 2000.
Recipients' eligibility for relief
Note: According to the U.S. Tax Code, the term “beneficial owner” means the person who is the owner
of income for tax purposes and who beneficially owns that income. This definition refers to the
quality of the account holder receiving the income (the “recipient”) rather than to the person who
has an economic interest in the business entity.
A recipient’s eligibility for relief at source is as follows:
Flow 1. Foreign account holders
Clearstream Banking customers that are foreign account holders and are the beneficial owners of the
U.S. securities held on their account must provide either a form W-8BEN or W-8EXP or W-8ECI in their
own name.
By virtue of the U.S. tax regulations, relief at source is available on interest payments from all U.S. debt
securities to the following beneficial owners:
Foreign persons and/or residents of a DTT country
A foreign person includes a Non-Resident Alien (NRA), a foreign corporation, a foreign partnership, a
foreign trust, a foreign estate and any other person that is not a U.S. person.
Any individual who is not a citizen or resident of the U.S.A. is an NRA.
Exemption at source from withholding tax and backup withholding tax is available on interest paid on
registered debt securities issued after 18 July 1984 and on OID paid on debt securities issued after
31 December 2000 to the beneficial owner of the securities.
Relief at source from withholding tax and backup withholding tax is available on interest paid on debt
securities issued prior to 18 July 1984 to the beneficial owner and who qualifies for the benefit of a
reduced rate of withholding tax in accordance with a DTT between its country of residence and the
U.S.A. and who meets the limitation on benefits provisions contained in the treaty, if any. The maximum
rate of withholding tax is defined in the relevant DTT in Appendix 1 on page A-3.
Claims for refund of withholding tax and backup withholding tax from the IRS are not available through
Clearstream Banking.
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A foreign person claiming exemption or a reduced rate of withholding tax according to the provisions of
an applicable DTT must submit a Certificate of Foreign Status of Beneficial Owner for U.S. Tax
Withholding (Form W-8BEN with part II completed) applicable with respect to U.S. debt securities.
Limitation of Benefits (LOB)
To determine whether an entity meets the limitation of benefits provisions of a treaty, the specific
provisions or articles under the treaty have to be consulted.
An entity eligible to benefit from a DTT may be subject to additional restrictions and exceptions. Most
DTTs contain a limitation of benefits clauses that allow foreign business entities, for example,
corporations or per se corporations, to benefit from the treaty rate on interest only if the additional
conditions are met.
Since 31 December 2002, any foreign corporations that have not indicated on their Form W-8BEN the
acknowledgement of the Limitation of Benefits are not entitled to the benefits of the relevant DTT.
The DTTs signed by the U.S.A. and currently in force are listed in Appendix 1 on page A-3.
Please consult your tax advisors for further information.
Foreign governments and other foreign organisations
Exemption at source from withholding tax and backup withholding tax is available to the following
beneficial owners that are recognised as tax exempt under U.S. law:
• Foreign governments;
• International organisations;
• Foreign central bank of issue (not wholly owned by the foreign sovereign);
• Foreign tax-exempt organisations, including foreign private foundations;
• Governments of U.S. possessions.
Claims for refund of withholding tax and backup withholding tax from the IRS are not available through
Clearstream Banking.
To claim an exception of withholding tax, the eligible recipients must submit a Certificate of Foreign
Government or other Foreign Organisation for U.S. Tax Withholding (Form W-8EXP) applicable with
respect to U.S. debt securities.
Foreign persons whose income is effectively connected with the conduct of a trade or business in the
U.S.A.
Exemption at source from withholding tax and backup withholding tax is available to a beneficial owner
of income from U.S. sources that is effectively connected with the conduct of a trade or business in the
U.S.A.
A reclaim of withholding tax is available through Clearstream Banking under certain conditions (see
“Reclaiming withholding tax from Clearstream Banking” on page 33).
Claims for refund of withholding tax and backup withholding tax from the IRS are not available through
Clearstream Banking.
To claim an exception of withholding tax, the eligible recipient must submit a Certificate of Foreign
Person's Claim for exemption from Withholding on income effectively connected with the conduct of a
trade or business in the U.S.A. (Form W-8ECI) applicable with respect to U.S. debt securities.
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Flow 2. U.S. persons
There are two categories of U.S. person for tax purposes, as follows:
• Legal entities
Legal entities include a sole proprietorship, a partnership or a corporation as well as other legal
entities such as trusts. These legal entities, if organised and incorporated in the U.S.A., are
considered to be U.S. persons for tax purposes. U.S. law distinguishes between grantor trusts,
simple trusts and complex trusts. Grantor trusts and simple trusts are considered to be flowthrough entities that have separate beneficial owners. Complex trusts are generally considered
to be the beneficial owners of U.S. source income.
• Individuals
An individual is a U.S. person for U.S. tax purposes if:
− He or she has the status of a citizen of the U.S.A., even if living abroad as long as he or she
holds a valid U.S. passport; or
− He or she is a non-U.S. person resident in the U.S.A. (resident alien). A resident alien must
meet either the green card test or the substantial presence test for the calendar year (from
1 January to 31 December).
By virtue of the U.S. tax regulations, exemption at source from withholding tax and backup withholding
tax is available on interest payment of all U.S. debt securities to the following U.S. persons:
U.S. exempt persons
1. U.S. persons exempt from backup withholding tax, even if they are not providing a Taxpayer
Identification Number (TIN):
− The U.S.A. or any of its agencies or instrumentalities;
− A state, the District of Columbia, a possession of the U.S.A., or any of their political
subdivisions or instrumentalities;
− Foreign government or any of its political subdivisions, agencies or instrumentalities;
− International organisation or any of its agencies or instrumentalities.
2. U.S. persons that might be exempt from backup withholding tax:
− U.S. corporation;
− Foreign central bank of issue;
− Financial institution;
− Entity registered at all times during the tax year under the Investment Company Act;
− Trust exempt from tax under the U.S. tax regulations.
These beneficial owners can be exempt from backup withholding tax under the following
conditions:
■
Furnish the correct TIN and certify it when required;
■
Submit a Request for Taxpayer Identification Number and Certification (Form W-9);
■
Report all taxable interest.
U.S. non-exempt persons
All U.S. persons considered as non-exempt can obtain an exemption from backup withholding tax under
the following conditions:
• Furnish the correct TIN and certify it when required;
• Submit a Request for Taxpayer Identification Number and Certification (Form W-9);
• Report all taxable interest.
Claims for refund of withholding tax and backup withholding tax from the IRS are not available through
Clearstream Banking.
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Flow 3. Qualified Intermediaries (QIs)
A QI is a foreign financial institution such as a bank, broker or asset manager that pays U.S. source
income to its customers and has signed a Qualified Intermediary Agreement (QIA) with the IRS.
An exemption or relief at source from withholding tax and backup withholding tax is available to a QI.
A reclaim of withholding tax is available through Clearstream Banking under certain conditions (see
“Reclaiming withholding tax from Clearstream Banking” on page 33).
Claims for refund of withholding tax and backup withholding tax from the IRS are not available through
Clearstream Banking.
To claim QI status, the customer must submit a Certificate of Foreign Intermediary, Foreign Flow-Throw
Entity, or certain U.S. Branches for U.S. Tax Withholding (Form W-8IMY) applicable with respect to U.S.
debt securities.
Flow 4. Non-Qualified Intermediaries (NQIs) and Flow-Through Entities (FTEs)
An NQI is a non-U.S. intermediary that does not become a QI owing to the fact that it has not signed QIA
with the IRS.
An FTE is:
• Foreign partnership;
• Foreign Simple Trust, Complex Trust or Grantor Trust; or
• Other entity that is considered fiscally transparent.
An exemption or relief at source from withholding tax and backup withholding tax is available to an NQI.
Claims for refund of withholding tax and backup withholding tax from the IRS are not available through
Clearstream Banking.
To claim NQI status, the customer must submit a Certificate of Foreign Intermediary, Foreign FlowThrow Entity, or certain U.S. Branches for U.S. Tax Withholding (Form W-8IMY) applicable with respect
to U.S. debt securities.
Reclaim of withholding tax
Reclaim through Clearstream Banking
In certain cases, customers can reclaim U.S. withholding tax through Clearstream Banking, as
explained in “Reclaiming withholding tax from Clearstream Banking” on page 33).
Note: Customers are urged to monitor their accounts in order to minimise the number of reclaim
requests.
Refund from the IRS
The claim for refund of withholding tax or backup withholding tax from the IRS is not available through
Clearstream Banking.
However, customers may apply directly through the IRS. The statutory deadline for claiming a refund of
withholding tax is three years from the time that the return was filed or two years from the time that the
tax was paid, whichever of such periods expires later. If no tax return was filed, the deadline for
claiming a refund of withholding tax through the IRS is two years from the time that the tax was paid.
Details of the refund procedures can be found on the IRS web site: www.irs.gov.
In order to support its customers, Clearstream Banking will provide the following documentation upon
request from the customer:
• A letter including general information on the procedure;
• A payment advice with details of the income payment and tax withheld;
• A copy of Form 1042-S.
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Customer requests should be sent, by an authenticated means of communication, to the attention of
OTL - Tax Services and including the following information:
• Account number;
• Security code and description;
• Payment date;
• Total holding;
• Name and address of the person to whom the documents should be mailed;
• Gross amount/net amount/tax amount.
Obtaining relief at source from withholding tax
Relief at source - Who can obtain relief at source?
Beneficial owners can obtain an exemption at source or relief at source from withholding tax on interest
from debt securities, as follows:
Rate applicable
at source
Eligible Recipients
Foreign persons and/or residents of a DTT country
See...
0% or DTT rate or 30%,
whichever is lower
Appendix 1 on
page A-3
Foreign governments and other foreign organisations
0%
-
Foreign persons whose income is effectively connected
with the conduct of a trade or business in the U.S.A.
0%
-
U.S. persons
0%
-
Qualified Intermediaries
0% or DTT rate or 30%,
whichever is lower
Appendix 1 on
page A-3
Non-Qualified Intermediaries and Flow-Through
Entities
0% or DTT rate or 30%,
whichever is lower
Appendix 1 on
page A-3
Relief at source - What documents are required to obtain relief at source?
There are different documentation requirements depending on whether the customer is:
• A foreign person and/or resident of a DTT country; or
• A foreign government or other foreign organisation; or
• A foreign person whose income is effectively connected with the conduct of a trade or business in
the U.S.A.; or
• A U.S. person; or
• A Qualified Intermediary; or
• A Non-Qualified Intermediary or a Flow-Through Entity.
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The documents to be completed and submitted to Clearstream Banking in order to obtain exemption at
source or relief at source are described in more detail in the following tables.
Document
See...
If the customer is a foreign person and/or a resident of a DTT country, this documentation must be
used:
Form W-8BEN: Certification of Foreign Status of Beneficial Owner for
U.S. Tax Withholding (Form W-8BEN with part II completed if the
customer is resident in a DTT country and claims DTT relief on interest
paid on pre-July 1984 bonds).
Appendix 4 on page A-14
(information purposes only)
Certification that provides certain statements regarding the beneficial owner of the securities.
Note: IRS Form W-8BEN with detailed instructions can be obtained from the IRS web site:
http://www.irs.gov/app/picklist/list/formsInstructions.html.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8BEN and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
By the first income payment, thereafter renewal by expiry. In the event of
changes, a new W-8BEN must be provided to Clearstream Banking within
30 days. The form is valid from the date of the signature until the end of the
third succeeding calendar year.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
income payment by 10:00 CET.
Copy or original?
Original required.
Withholding Statement - Non-U.S. beneficial owners
Appendix 9 on page A-24
One time certification that provides additional payment information.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8BEN and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
Once. Valid until revoked by the customer. In the event of changes, a new
Withholding Statement must be provided to Clearstream Banking within 30
days.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
income payment by 10:00 CET.
Copy or original?
Original required.
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Document
See...
If the customer is a foreign government or other foreign organisation, this documentation must be
used:
Form W-8EXP: Certificate of Foreign Government or other Foreign
Organisation for U.S. Tax Withholding
Appendix 5 on page A-15
(information purposes only)
Certification that qualifies the customer that is a foreign government or other foreign organisation for
an exemption.
Note: IRS Form W-8EXP with detailed instructions can be obtained from the IRS web site:
http://www.irs.gov/app/picklist/list/formsInstructions.html.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8EXP and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
By the first income payment, thereafter renewal upon expiry. In the event
of changes, a new W-8EXP must be provided to Clearstream Banking
within 30 days. The form is valid from the date of the signature until the
end of the third succeeding calendar year.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
income payment by 10:00 CET.
Copy or original?
Original required.
Withholding Statement - Non-U.S. beneficial owners
Appendix 9 on page A-24
One time certification that provides additional payment information.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8EXP and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
Once. Valid until revoked by the customer. In the event of changes, a new
Withholding Statement must be provided to Clearstream Banking within 30
days.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
income payment by 10:00 CET.
Copy or original?
Original required.
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Document
See...
If the customer is a beneficial owner whose income is effectively connected with the conduct of a
trade or business in the U.S.A., this documentation must be used:
Form W-8ECI: Certification of Foreign Person's Claim for Exemption
from Withholding on Income Effectively Connected with the conduct of
a Trade or Business in the U.S.A.
Appendix 6 on page A-17
(information purposes only)
Certification that qualifies the eligible recipient as a beneficial owner whose income is effectively
connected with the conduct of a trade or business in the U.S.A.
Note: IRS Form W-8ECI with detailed instructions can be obtained from the IRS web site:
http://www.irs.gov/app/picklist/list/formsInstructions.html.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8ECI and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
By the first income payment, thereafter renewal upon expiry. In the event
of changes, a new W-8ECI must be provided to Clearstream Banking within
30 days. The form is valid from the date of the signature until the end of the
third succeeding calendar year.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
income payment by 10:00 CET.
Copy or original?
Original required.
Withholding Statement - Non-U.S. beneficial owners
Appendix 9 on page A-24
One time certification that provides additional payment information.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8ECI and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
Once. Valid until revoked by the customer. In the event of changes, a new
Withholding Statement must be provided to Clearstream Banking within 30
days.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
income payment by 10:00 CET.
Copy or original?
Original required.
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Document
See...
If the customer is a U.S. person, this documentation must be used:
Form W-9: Request for Taxpayer Identification Number and
Certification
Appendix 8 on page A-20
(information purposes only)
One time certification, the purpose of which is to provide the correct Taxpayer Identification Number
(TIN), to certify that the person is not subject to backup withholding tax or to claim exemption from
backup withholding tax by a U.S. exempt person.
Note: IRS Form W-9 with detailed instructions can be obtained from the IRS web site:
http://www.irs.gov/app/picklist/list/formsInstructions.html.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-9 and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
Once. Valid until revoked by the customer. In the event of changes, a new
Withholding Statement must be provided to Clearstream Banking within 30
days.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
income payment by 10:00 CET.
Copy or original?
Original required.
Withholding Statement - U.S. person
Appendix 10 on page A-27
One time certification that provides additional payment information.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-9 and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
Once. Valid until revoked by the customer. In the event of changes, a new
Withholding Statement must be provided to Clearstream Banking within 30
days.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
income payment by 10:00 CET.
Copy or original?
Original required.
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Document
See...
If the customer is a Qualified Intermediary type A, this documentation must be used:
Form W-8IMY: Certificate of Foreign Intermediary, Foreign FlowThrough Entity, or Certain U.S. Branches for U.S. Tax Withholding
Appendix 7 on page A-18
(information purposes only)
Certification that qualifies the eligible recipient as a QI.
Note: IRS Form W-8IMY with detailed instructions can be obtained from the IRS web site:
http://www.irs.gov/app/picklist/list/formsInstructions.html.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8IMY and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
By the first income payment, renewal upon expiry. In the event of changes,
a new W-8IMY must be provided to Clearstream Banking within 30 days.
The form is valid from the date of the signature until the end of the third
succeeding calendar year, unless the QI-EIN is completed, in which case
the W-8IMY is valid until revoked by the customer.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
income payment by 10:00 CET.
Copy or original?
Original required.
Withholding Statement QI - A Account
Appendix 11 on page A-29
Withholding Statement QI - A Account is a one-time certification of a QI that has assumed primary
NRA withholding responsibility and backup withholding and 1099 reporting responsibility with
respect to all U.S. securities held in the account.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8IMY and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
Once. Valid until revoked by the customer. In the event of changes, a new
Withholding Statement must be provided to Clearstream Banking within 30
days.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
income payment by 10:00 CET.
Copy or original?
Original required.
March 2013
26 of 62
Clearstream Banking
Customer Tax Guide - United States of America
U.S.A. - Debt securities
Document
See...
If the customer is a Qualified Intermediary type B, this documentation must be used:
Form W-8IMY: Certificate of Foreign Intermediary, Foreign FlowThrough Entity, or Certain U.S. Branches for U.S. Tax Withholding
Appendix 7 on page A-18
(information purposes only)
Certification that qualifies the eligible recipient as a QI.
Note: IRS Form W-8IMY with detailed instructions can be obtained from the IRS web site:
http://www.irs.gov/app/picklist/list/formsInstructions.html.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8IMY and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
By the first income payment, renewal upon expiry. In the event of changes,
a new W-8IMY must be provided to Clearstream Banking within 30 days.
The form is valid from the date of the signature until the end of the third
succeeding calendar year, unless the QI-EIN is completed, in which case
the W-8IMY is valid until revoked by the customer.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
income payment by 10:00 CET.
Copy or original?
Original required.
Withholding Statement QI - B Account
Appendix 12 on page A-32
Withholding Statement QI - B Account is a one-time certification of a QI that has assumed primary
NRA withholding responsibility and has not assumed backup withholding and 1099 reporting
responsibility with respect to all U.S. securities held in the account.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8IMY and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
Once. Valid until revoked by the customer. In the event of changes, a new
Withholding Statement must be provided to Clearstream Banking within 30
days.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
income payment by 10:00 CET.
Copy or original?
Original required.
Clearstream Banking
Customer Tax Guide - United States of America
March 2013
27 of 62
U.S.A. - Debt securities
Document (cont’d)
See...
If the customer is a Qualified Intermediary type B, this documentation must be used: (cont’d)
Form W-9: Request for Taxpayer Identification Number and
Certification
Appendix 8 on page A-20
(information purposes only)
Applicable only for QI type B customers who hold U.S. securities on behalf of U.S. non-exempt
persons.
One-time certification, the purpose of which is to provide the correct Taxpayer Identification Number
(TIN) of the U.S. non-exempt person.
Note: IRS Form W-9 with detailed instructions can be obtained from the IRS web site:
http://www.irs.gov/app/picklist/list/formsInstructions.html.
How many are provided?
Per U.S. non-exempt person.
Who completes it?
U.S. non-exempt person.
How often is it provided?
Once. Valid until revoked. In the event of changes, a new W-9 must be
provided to Clearstream Banking within 30 days.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
income payment by 10:00 CET.
Copy or original?
Original required.
Allocation Information
-
Provides certain statements regarding the allocation of the payment to the underlying beneficial
owners of the securities.
QI type B customers that have an omnibus account for U.S. non-exempt persons are required to
provide a Form W-9 from each U.S. non-exempt person and allocation information per income
payment. The allocation information must include the following details:
• Account number;
• Security code and description;
• Payment date;
• Total holding;
• Breakdown per U.S. non-exempt person.
How many are provided?
Per Clearstream Banking account or specified set of Clearstream Banking
accounts.
Who completes it?
Customer.
How often is it provided?
Prior to each income payment.
When is it provided?
The customer must submit the completed form to Clearstream Banking at
least two business days prior to the relevant income payment by 10:00 CET.
Copy or original?
Allocation information must be submitted via SWIFT or CreationOnline.
March 2013
28 of 62
Clearstream Banking
Customer Tax Guide - United States of America
U.S.A. - Debt securities
Document
See...
If the customer is a Qualified Intermediary type C, this documentation must be used:
Form W-8IMY: Certificate of Foreign Intermediary, Foreign FlowThrough Entity, or Certain U.S. Branches for U.S. Tax Withholding
Appendix 7 on page A-18
(information purposes only)
Certification that qualifies the eligible recipient as a QI.
Note: IRS Form W-8IMY with detailed instructions can be obtained from the IRS web site:
http://www.irs.gov/app/picklist/list/formsInstructions.html.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8IMY and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
By the first income payment, renewal upon expiry. In the event of changes,
a new W-8IMY must be provided to Clearstream Banking within 30 days.
The form is valid from the date of the signature until the end of the third
succeeding calendar year, unless the QI-EIN is completed, in which case
the W-8IMY is valid until revoked by the customer.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
income payment by 10:00 CET.
Copy or original?
Original required.
Withholding Statement QI - C Account
Appendix 13 on page A-35
Withholding Statement QI - C Account is a one-time certification of a QI that has not assumed primary
NRA withholding responsibility and has not assumed backup withholding and 1099 reporting
responsibility with respect to all U.S. securities held in the account.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8IMY and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
Once. Valid until revoked by the customer. In the event of changes, a new
Withholding Statement must be provided to Clearstream Banking within 30
days.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
income payment by 10:00 CET.
Copy or original?
Original required.
Clearstream Banking
Customer Tax Guide - United States of America
March 2013
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U.S.A. - Debt securities
Document (cont’d)
See...
If the customer is a Qualified Intermediary type C, this documentation must be used: (cont’d)
Form W-9: Request for Taxpayer Identification Number and
Certification
Appendix 8 on page A-20
(information purposes only)
Applicable only for QI type C customers who hold U.S. securities on behalf of U.S. non-exempt
persons.
One-time certification, the purpose of which is to provide the correct Taxpayer Identification Number
(TIN) of the U.S. non-exempt person.
Note: IRS Form W-9 with detailed instructions can be obtained from the IRS web site:
http://www.irs.gov/app/picklist/list/formsInstructions.html.
How many are provided?
Per U.S. non-exempt person.
Who completes it?
U.S. non-exempt person.
How often is it provided?
Once. Valid until revoked. In the event of changes, a new W-9 must be
provided to Clearstream Banking within 30 days.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
income payment by 10:00 CET.
Copy or original?
Original required.
Allocation Information
-
Provides certain statements regarding the allocation of the payment to the underlying beneficial
owners of the securities.
• QI type C customers that have an omnibus account for non-U.S. beneficial owners and U.S.
exempt persons are required to provide allocation information per income payment in order to
be entitled to relief or exemption from U.S. withholding tax. The allocation information must
include the following details:
Account number; Security code and description; Payment date; Total holding; Withholding
tax rates to be applied per holding.
• QI type C customers that have an omnibus account for U.S. non-exempt persons are required
to provide a Form W-9 from each U.S. non-exempt person and allocation information per
income payment. The allocation information must include the following details:
Account number; Security code and description; Payment date; Total holding; Breakdown
per U.S. non-exempt person.
How many are provided?
Per Clearstream Banking account or specified set of Clearstream Banking
accounts.
Who completes it?
Customer.
How often is it provided?
Prior to each income payment.
When is it provided?
The customer must submit the completed form to Clearstream Banking at
least two business days prior to the relevant income payment by 10:00 CET.
Copy or original?
Allocation information must be submitted via SWIFT or CreationOnline.
March 2013
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Clearstream Banking
Customer Tax Guide - United States of America
U.S.A. - Debt securities
Document
See...
If the customer is a Non-Qualified Intermediary (NQI) or Flow-Through Entity (FTE), this
documentation must be used:
Form W-8IMY: Certificate of Foreign Intermediary, Foreign FlowThrough Entity, or Certain U.S. Branches for U.S. Tax Withholding
Appendix 7 on page A-18
(information purposes only)
Certification that qualifies the eligible recipient as an NQI or a Flow-Through Entity.
Note: IRS Form W-8IMY with detailed instructions can be obtained from the IRS web site:
http://www.irs.gov/app/picklist/list/formsInstructions.html.
How many are provided?
One per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8IMY and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
By the first income payment, renewal upon expiry. In case of changes, a
new W-8IMY must be provided to Clearstream Banking within 30 days. The
form is valid from the date of the signature until the end of the third
succeeding calendar year.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
income payment by 10:00 CET.
Copy or original?
Original required.
Withholding Statement - NQI account
Appendix 14 on page A-39
One time certification that provides additional payment information.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8IMY and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
Once. Valid until revoked by the customer. In the event of changes, a new
Withholding Statement must be provided to Clearstream Banking within
30 days.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the
relevant dividend payment by 10:00 CET.
Copy or original?
Original required.
Clearstream Banking
Customer Tax Guide - United States of America
March 2013
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U.S.A. - Debt securities
Document (cont’d)
See...
If the customer is a Non-Qualified Intermediary (NQI) or Flow-Through Entity (FTE), this
documentation must be used: (cont’d)
Form W-8BEN, W-8EXP, W-8ECI, W-8IMY, W-9
Appendix 4 on page A-14
Appendix 5 on page A-15
Appendix 6 on page A-17
Appendix 7 on page A-18
Appendix 8 on page A-20
(information purposes only)
The customer must provide this documentation in addition to the form W-8IMY if the NQI has an
account structure containing one or more of the following:
• One account for each U.S. non-exempt person;
• One account for all U.S. exempt persons;
• One account for each non-U.S. beneficial owner;
• One account for each QI withholding and reporting pool;
• One account for each underlying NQI with a single beneficial owner.
The IRS Forms W-8BEN, W-8EXP, W-8ECI, W-8IMY or W-9 with their respective detailed instructions
can be obtained from the IRS web site: http://www.irs.gov/app/picklist/list/formsInstructions.html.
How many are provided?
One Form W-8BEN, W-8EXP or W-8ECI from each non-U.S. beneficial
owner;
One Form W-8IMY from each QI or NQI;
One Form W-9 from each U.S. non-exempt and U.S. exempt person.
Who completes it?
Forms W-8BEN, W-8EXP or W-8ECI: Beneficial owner;
Form W-8IMY: Underlying QI or NQI;
Form W-9: U.S. non-exempt, U.S. exempt person.
How often is it provided?
By the first income payment, thereafter renewal upon expiry. In case of
changes, a new form must be provided to Clearstream Banking within 30
days. W-9 is valid until revoked, forms W-8 are valid from the date of the
signature until the end of the third succeeding calendar year.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
income payment by 10:00 CET.
Copy or original?
Original required.
Relief at source - When is the deadline for receipt of documents?
Documentation must be received by Clearstream Banking by the following deadlines:
Document
Deadline for receipt by Clearstream Banking
W-8BEN, W-8EXP, W-8ECI, W-8IMY, W-9
Two business days before first income payment by 10:00 CET.
Withholding Statement
Two business days before first income payment by 10:00 CET.
Allocation Information
Two business days before the relevant income payment by 10:00 CET.
March 2013
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Clearstream Banking
Customer Tax Guide - United States of America
U.S.A. - Debt securities
Reclaiming withholding tax from Clearstream Banking
Tax reclaim - Who can reclaim withholding tax?
Recipients can reclaim withholding tax on interest from Clearstream Banking as follows:
Effective rate of tax
after refund a
Tax refund
available a
0% or DTT treaty rate
or 30%, whichever is lower
30% or 30% minus
the DTT rate b
Eligible Recipients
Qualified Intermediaries
See...
Appendix 1 on
page A-3
a. Expressed as a percentage of the gross interest amount.
b. Amount of relief will be 0% if the DTT rate exceeds 30%.
Tax reclaim - In which cases may Clearstream Banking accept reclaims?
Customers may be eligible to reclaim U.S. withholding tax through Clearstream Banking in the
following circumstances:
• The customer has not received pre-notification of a payment.
If, for example, the payment is not included in the Income Pre-Advice Report, the customer will
be entitled to an automatic adjustment of tax over-withheld without having to submit the reclaim
form. If the customer has been notified of payments by Clearstream Banking, a reclaim form
must be submitted in order to be eligible to reclaim U.S. withholding tax.
• The customer has not provided the required allocation information.
If a customer fails to supply the required allocation information for a payment within the
Clearstream Banking deadline (two days before the income payment date), the customer must
both submit a completed reclaim form and send the required allocation information to
Clearstream Banking before the end of the calendar year in which the payment was made. After
this period, Clearstream Banking will not accept reclaims and the customer will have to request
a refund directly from the IRS.
• The customer does not hold the securities in a certified account.
If, for example, the customer transferred securities between accounts for netting purposes but
did not allocate the securities to a certified account on a record date, the customer may reclaim
the tax over-withheld. Clearstream Banking will apply the appropriate withholding tax to the
account where the securities were held on record date in accordance with the documentation in
place for the account.
Tax reclaim - What documents are required?
The documents to be completed and submitted to Clearstream Banking in order to reclaim withholding
tax on interest from Clearstream Banking are described in more details in the following tables.
Document
See...
Statement to Reclaim U.S. Withholding Tax
Appendix 16 on page A-46
Clearstream Banking's reclaim form identifying the status of the customer and the reason for reclaim
and including security and payment details, as well as the applicable tax rates.
Who completes it?
Customer.
How often is it provided?
Per reclaim application.
When is it provided?
Before the end of the calendar year in which the payment was made.
Copy or original?
Original required.
Clearstream Banking
Customer Tax Guide - United States of America
March 2013
33 of 62
U.S.A. - Debt securities
Document (cont’d)
See...
Allocation Information
-
Provides certain statements regarding the allocation of the payment to the underling beneficial
owners of the securities. QI type B and C customers that have an omnibus account for non-U.S.
beneficial owners and U.S. exempt persons but who failed to supply the required allocation
information for a payment within the Clearstream Banking deadline (two days before the income
payment date) must provide allocation information per reclaim application.
The allocation information must include the following details:
• Account number;
• Security code and description;
• Payment date;
• Total holding;
• Withholding tax rates to be applied per holding.
Who completes it?
Customer (QI type B or C) with an omnibus account.
How often is it provided?
Per reclaim application.
When is it provided?
Before the end of the calendar year in which the payment was made.
Copy or original?
Allocation information must be submitted via SWIFT or CreationOnline.
Tax reclaim - When is the deadline for receipt of documents?
Documentation must be received by Clearstream Banking by the following dates:
Document
Deadline for receipt by Clearstream Banking
Statement to Reclaim U.S.
Withholding Tax
Before the end of the calendar year in which the payment was made.
Allocation Information
Before the end of the calendar year in which the payment was made.
Tax reclaim - How are reimbursements effected?
The QI Agreement with the IRS allows Clearstream Banking to adjust over-withheld tax either by setting
it off against subsequent withholding (“set off”) or by reimbursement.
Clearstream Banking makes weekly deposits via the Electronic Federal Tax Payment System (EFTPS)
such that, at the precise time that the customer submits a valid reclaim request, there may not be
sufficient funds in Clearstream Banking’s tax account to make a reimbursement.
Clearstream Banking processes reimbursements in the order received and only at such time as funds
in the tax account are sufficient. If a reimbursement could not be made before the end of the calendar
year due to insufficient funds in the tax acount, customers must apply for a refund directly fro the IRS.
All reimbursements are made by Clearstream Banking in U.S. Dollars (USD). For income payments
made in a currency other than USD, the tax amount to be reimbursed is converted into USD at the
foreign exchange rate prevailing at the time of the withholding.
March 2013
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Clearstream Banking
Customer Tax Guide - United States of America
U.S.A. - Equities
Equities
Who can obtain relief at source through Clearstream Banking?
Flow 1. Equities: Foreign account holders
No
Is the eligible recipient a Foreign Account
Holder / NRA?
The eligible recipient is a U.S. Account Holder
/ U.S. person (see page 36).
Yes
No
Is the eligible recipient a Direct Account
Holder, that is a Beneficial Owner?
The eligible recipient is a Qualified
Intermediary (QI) (see page 37) or
a Non-Qualified Intermediary (NQI) /
Flow-Through Entity (FTE) (see page 38).
Yes
No
Correct A. W-8BEN, W-8ECI, W-8EXP (except
W-8IMY); and B. Withholding Statement?
Application of Presumption Rules
(see page 39)
Yes
Yes
New contradictory information?
No
Documentation validity: A. Reason to know;
or B. Actual knowledge?
Yes
Yes
Income from U.S. securities?
Yes
No
Account holder delivers corrected details
(for example, different WHT rate) to
Clearstream Banking prior to payment?
No
No withholding
tax impact.
Application of Presumption Rules
(see page 39).
U.S. Equities,
GDRs
DTT rate, if applicable;
else, 30%; W-8BEN
Exemption at source; 0%;
W-8EXP, W-8EC.
IDRs
DTT rate, if applicable;
else, 30%; W-8BEN
N.B.: If Belgian issuer
(and so no exemption at
source): 30%.
1042-S reporting
(see page 58).
Exemption at source; 0%;
W-8EXP, W-8EC.
ADRs
Clearstream Banking
Customer Tax Guide - United States of America
Not taxable / not
reportable
March 2013
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U.S.A. - Equities
Flow 2. Equities: U.S. account holders / U.S. persons
Is the eligible recipient a U.S. Account
Holder / U.S. person?
No
The eligible recipient is a Foreign Account
Holder / NRA (see page 35).
Yes
Is the eligible recipient
the Direct Account Holder?
No
The eligible recipient is a Qualified
Intermediary (QI) (see page 37) or
a Non-Qualified Intermediary (NQI) / FlowThrough Entity (FTE) (see page 38).
Yes
Is the recipient U.S. non-exempt,
undocumented?
Yes
No
Application of backup withholding and
Presumption Rules (see page 39)
before 1 Jan 2003. As of 1 Jan 2003,
no U.S. securities can be held for U.S.
undocumented recipients.
No
Is the recipient U.S. non-exempt,
documented but undisclosed
(natural person or per se or
other corporation)?
Yes
Does the recipient have
documentary evidence?
Yes
No
Is the recipient U.S. exempt,
documented and disclosed?
Yes
No
Has the recipient provided:
A. Valid form W9 with the
“Exempt” box checked; and
B. Withholding statement.
Yes
No
Is the recipient U.S. non-exempt,
documented and disclosed
(natural person or per se or
other corporation)?
Yes
Has the recipient provided:
A. Valid form W9; and
B. Withholding statement.
Yes
No
Income from U.S. securities?
No
No withholding
tax impact.
Yes
30% on U.S. Equities,
GDRs and IDRs.
1099 reporting
(see page 58).
0% on U.S. Equities,
GDRs and IDRs.
March 2013
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Clearstream Banking
Customer Tax Guide - United States of America
U.S.A. - Equities
Flow 3. Equities: Qualified Intermediaries (QIs)
No
Is the eligible recipient an Intermediary
or a Flow-Through Entity (FTE)?
Yes
No
Is the eligible recipient a Qualified
Intermediary (QI) or a Withholding
Foreign Partnership (WFP)?
The eligible recipient is a
Foreign Account Holder / NRA (see page 35)
or a U.S. account holder
or U.S. person (see page 36).
The eligible recipient is a Non-Qualified
Intermediary (NQI) or FTE (see page 38).
Yes
No
Can Clearstream Banking reliably
associate the payment with:
A. A valid W-8IMY plus Withholding
Statement provided by the QI/WFP; and
B. A withholding rate pool as per the
Withholding Statement?
Yes
Application of Presumption Rules
(see page 39).
Income from
U.S. securities?
No
No withholding
tax impact.
Yes
QI A
QI B
All
Omnibus
Account, 0%
1042-S reporting
(see page 58).
Non-U.S. and
U.S. exempt
U.S. non-exempt
Omnibus
Account, 0%
Omnibus Account,
0%, W-9 +
Allocation
Information
1099 reporting
(see page 58).
Segregated
Account, 0%, W-9
QI C
Non-U.S. and
U.S. exempt
Omnibus
Account, 30% /
0% or DTT rate Allocation
Information
Segregated
Account, 0% or
DTT rate
Segregated
Account, 30%
U.S. non-exempt
Omnibus Account,
0%, W-9 +
Allocation
Information
U.S.
exempt
For Non-U.S.:
1042-S reporting
(see page 58);
For U.S. exempt:
No reporting.
Documented NonU.S. tax relief;
DTT rate account
No reporting.
Documented NonU.S. - no tax relief
requested;
Undocumented
Non-U.S. no tax
relief
1042-S reporting
(see page 58).
1099 reporting
(see page 58).
Segregated
Account, 0%, W-9
Clearstream Banking
Customer Tax Guide - United States of America
March 2013
37 of 62
U.S.A. - Equities
Flow 4. Equities: Non-Qualified Intermediaries (NQIs) or Flow-Through Entities (FTEs)
Is the eligible recipient an Intermediary
or a Flow-Through Entity (FTE)?
No
The eligible recipient is a
Foreign Account Holder / NRA (see page 35)
or a U.S. account holder
or U.S. person (see page 36).
No
The eligible recipient is a Qualified
Intermediary (QI) or a Withholding Foreign
Partnership (WFP) (see page 37).
Yes
Is the eligible recipient a Non-Qualified
Intermediary (NQI) or an FTE?
Yes
A. Has Clearstream Banking received a valid
W-8IMY plus Withholding Statement provided
by the NQI or FTE; and
B. Can Clearstream Banking reliably
associate the payment with valid
documentation provided by account holders
that are not themselves NQI or FTE (W-8BEN,
W-8ECI, W-8EXP, W-8IMY, W-9)?
No
Yes
Application of Presumption Rules
(see page 39).
Income from U.S.
securities?
No
No withholding
tax impact.
Yes
Segregated
Account
Omnibus
Account
March 2013
38 of 62
U.S. non-exempt
0%, W-9
1099 reporting
(see page 58).
U.S. exempt
0%, W-9
No reporting.
Non-U.S. beneficial
owner, tax relief
0% / DTT rate,
W-8BEN, W-8EXP,
W-8ECI
QI withholding and
reporting pool
Rate per withholding
and reporting pool,
W-8IMY
Non-U.S. beneficial
owner, no tax relief
30% / 0%, W-8BEN
NQI with single
beneficial owner
0% / DTT rate,
W-8IMY, W-8BEN, W8EXP, W-8ECI, W-9
Non-U.S. beneficial
owner, U.S. taxexempt, tax relief
0% / DTT rate,
W-8BEN, W-8EXP,
W-8ECI, W-9,
Allocation
Information
Non-U.S.:
1042-S reporting;
U.S. exempt:
No reporting.
U.S. non-exempt
0%, W-9,
Allocation
Information
1099 reporting.
1042-S reporting
(see page 58).
Non-U.S.:
1042-S reporting
(see page 58);
U.S. exempt:
No reporting;
U.S. non-exempt:
1099 reporting
(see page 58).
Clearstream Banking
Customer Tax Guide - United States of America
U.S.A. - Equities
Summary of relief available
The standard rate of withholding tax on dividends is 30%. The current backup withholding rate is 28%.
Know Your Customer (KYC) Rules
The KYC Rules refer to the applicable laws, regulations, rules and administrative practices and
procedures, identified in the attachments to the Qualified Intermediary Agreement (QIA), governing the
requirements of the QI to obtain documentation confirming the identify of the QI's account holders.
Details on the KYC Rules are published on the IRS web site: www.irs.gov/.
Presumption Rules
A QI must generally apply the Presumption Rules to determine the status of an account holder if it
cannot reliably associate a payment with valid documentation from that account holder. A QI agreement
provides that an amount subject to withholding tax that is paid outside the U.S.A. is presumed made to
an undocumented foreign account holder.
According to the Presumption Rules, if a payee is a corporation, a withholding agent (such as a QI) shall
not treat the payee as the beneficial owner of the income if the withholding agent knows, or has reason
to know, that the payee is not the beneficial owner. For this purpose a withholding agent has reason to
know that the payee is not the beneficial owner of income if documentary evidence indicates that the
payee is a bank, broker, intermediary, custodian, or other agent, or is treated as such a person under
the U.S. regulations. Even though the QI may not have documentary evidence in this case, interpretation
of U.S. regulations provides that a payer may treat a payee as a financial institution (bank) if the
person's name (including a foreign name such as “Banco” or “Banque”) reasonably indicates that the
payee is a financial institution.
Therefore, if the name of the Clearstream Banking customer reasonably indicates that it is a bank,
Clearstream Banking will treat it as such an entity and will not treat the bank as the beneficial owner of
the income. Without documentation (that is, W-8BEN, W-8EXP or W-8ECI) the bank will, as a result,
default to Non-Qualified Intermediary (NQI) status subject to maximum withholding tax rate of 30% at
source.
Foreign exchange
For withholding and reporting purposes, the IRS requires that all information be made in U.S. dollars
(USD). Tax withheld is converted to USD, based on the average weekly foreign exchange rate applicable
at the time of withholding. The foreign exchange conversion is provided by the Treasury department of
Clearstream Banking and is obtained in a manner consistent with the IRS regulations.
Reimbursement of reclaims will be made in USD for the equivalent foreign currency of tax withheld on
the relevant income payment, based upon the foreign exchange conversion rate at the time of
withholding.
Equities - liability to withholding tax
Equities not subject to withholding tax or backup withholding tax
Dividends on American Depository Receipts (ADRs) are not subject to U.S. withholding tax. Foreign
withholding tax may be applied at source.
Equities subject to both withholding tax and backup withholding tax
Dividends on the following equities are subject to withholding tax and to backup withholding tax:
• DTCC Eligible Equities and Equity Products;
• International Depository Receipts (IDRs);
• Global Depository Receipts (GDRs).
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Equities subject to withholding tax but where tax is withheld at source
Dividends paid on IDRs issued by Belgian Overseas Issuing Corporation (BOIC) or Soges Fiducem are
subject to U.S. withholding tax, which is withheld at source regardless of the QI status, and the new U.S.
tax regulations are not applied.
Reporting of these securities for 1099 and 1042-S information reporting purposes is required.
Exemption or relief at source in this case is not possible unless and until Belgian issuers change their
practices. The refund procedure on such dividends is to make a refund request directly with the IRS.
Recipients' eligibility for relief
According to the U.S. Tax Code, the term “beneficial owner” means the person who is the owner of
income for tax purposes and who beneficially owns that income. This definition refers to the quality of
the account holder receiving the income (the “recipient”) rather than to the person who has an
economic interest in the business entity.
A recipient’s eligibility for relief at source is as follows:
Flow 1. Foreign account holders
Clearstream Banking customers that are foreign account holders and are the beneficial owners of the
U.S. securities held on their account must provide a form W-8BEN, W-8EXP or W-8ECI in their own name.
By virtue of the U.S. tax regulations, relief at source is available on dividend payments from all U.S.
equities to the following beneficial owners:
Foreign persons and/or residents of a DTT country
A foreign person includes a Non-Resident Alien (NRA), a foreign corporation, a foreign partnership, a
foreign trust, a foreign estate and any other person that is not a U.S. person.
Any individual who is not a citizen or resident of the U.S.A. is an NRA.
Relief at source from withholding tax and backup withholding tax is available on dividends paid on
equities to the beneficial owner and who qualifies for the benefit of a reduced rate of withholding tax in
accordance with a DTT between its country of residence and the U.S.A. and who meets the limitation on
benefits provisions contained in the treaty, if any. The maximum rate of withholding tax is defined in the
relevant DTT in Appendix 2 on page A-5.
Claim for refund of withholding tax and backup withholding tax from the IRS is not available through
Clearstream Banking.
A foreign person claiming exemption or a reduced rate of withholding tax according to the provisions of
an applicable DTT must submit a Certificate of Foreign Status of Beneficial Owner for U.S. Tax
Withholding (Form W-8BEN with part II completed) applicable with respect to U.S. equities.
Limitation of Benefits (LOB)
To determine whether an entity meets the limitation of benefits provisions to a treaty, the specific
provisions or articles under the treaty have to be consulted.
An entity eligible to benefit from a DTT may be subject to additional restrictions and exceptions. Most
DTTs contain a limitation of benefits clauses that allow foreign business entities, for example,
corporations or per se corporations, to benefit from the treaty rate on dividends only if the additional
conditions are met.
Since 31 December 2002, any foreign corporations that have not indicated on their Form W-8BEN the
acknowledgement of the Limitation of Benefits are not entitled to the benefits of the relevant DTT.
The DTTs signed by the U.S.A. and currently in force are listed in Appendix 2 on page A-5. Please
consult your tax advisors for further information.
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U.S.A. - Equities
Foreign governments and other foreign organisations
Exemption at source from withholding tax and backup withholding tax is available to the following
beneficial owners that are recognised as tax exempt under the U.S. law:
• Foreign governments;
• International organisations;
• Foreign central bank of issue (not wholly owned by the foreign sovereign);
• Foreign tax-exempt organisations, including foreign private foundations;
• Government of a U.S. possession.
Claims for refund of withholding tax and backup withholding tax from the IRS are not available through
Clearstream Banking. To claim an exception of withholding tax the eligible recipients have to submit a
Certificate of Foreign Government or other Foreign Organisation for U.S. Tax Withholding (Form W8EXP) applicable with respect to U.S. equities.
Foreign persons whose income is effectively connected with the conduct of a trade or business in the U.S.A.
Exemption at source from withholding tax and backup withholding tax is available to a beneficial owner of
income from U.S. sources that is effectively connected with the conduct of a trade or business in the U.S.A.
Claims for refund of withholding tax and backup withholding tax from the IRS are not available through
Clearstream Banking. To claim an exception of withholding tax the eligible recipient must submit a
Certificate of Foreign Person's Claim for exemption from Withholding on income effectively connected
with the conduct of a trade or business in the U.S.A. (Form W-8ECI) applicable with respect to U.S.
equities.
Flow 2. U.S. persons
There are two categories of U.S. Person for tax purposes, as follows:
• Legal entities
Legal entities include a sole proprietorship, a partnership or a corporation as well as other legal
entities such as trusts. These legal entities, if organised and incorporated in the U.S.A., are
considered to be U.S. Persons for tax purposes. U.S. law distinguishes between grantor trusts,
simple trusts and complex trusts. Grantor trusts and simple trusts are considered to be flowthrough entities that have separate beneficial owners. Complex trusts are generally considered
to be the beneficial owners of U.S. source income.
• Individuals
An individual is a U.S. Person for U.S. tax purposes if:
− He or she has the status of a citizen of the U.S.A., even if living abroad as long as he or she
holds a valid U.S. passport; or
− He or she is a non-U.S. person resident in the U.S.A. (resident alien). A resident alien must
meet either the green card test or the substantial presence test for the calendar year (from 1
January to 31 December).
By virtue of the U.S. tax regulations, exemption at source from withholding tax and backup withholding
tax is available on interest payment of all U.S. debt securities to the following U.S. persons:
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U.S. exempt persons
1. U.S. persons exempt from backup withholding tax, even if they are not providing a Taxpayer
Identification Number (TIN):
− The United States or any of its agencies or instrumentalities;
− A state, the District of Columbia, a possession of the U.S.A., or any of their political
subdivisions or instrumentalities;
− Foreign government or any of its political subdivisions, agencies or instrumentalities;
− International organisation or any of its agencies or instrumentalities.
2. U.S. persons that might be exempt from backup withholding tax:
− U.S. corporation;
− Foreign central bank of issue;
− Financial institution;
− Entity registered at all times during the tax year under the Investment Company Act;
− Trust exempt from tax under the U.S. tax regulations.
These beneficial owners can be exempt from backup withholding tax under the following
conditions:
■
Furnish the correct TIN and certify it when required;
■
Submit a Request for Taxpayer Identification Number and Certification (Form W-9);
■
Report all taxable dividends.
U.S. non-exempt persons
All U.S. persons considered as non-exempt can obtain an exemption from backup withholding tax under
the following conditions:
• Furnish the correct TIN and certify it when required;
• Submit a Request for Taxpayer Identification Number and Certification (Form W-9);
• Report all taxable dividends.
Claims for refund of withholding tax and backup withholding tax from the IRS are not available through
Clearstream Banking.
Flow 3. Qualified Intermediaries (QIs)
A QI is a foreign financial institution such as a bank, broker or asset manager that pays U.S. source
income to its customers and has signed a Qualified Intermediary Agreement (QIA) with the IRS.
An exemption or relief at source from withholding tax and backup withholding tax is available to a QI.
A reclaim of withholding tax is available through Clearstream Banking under certain conditions (see
“Reclaiming withholding tax from Clearstream Banking” on page 56).
Claims for refund of withholding tax and backup withholding tax from the IRS are not available through
Clearstream Banking.
To claim its QI status the customer must submit a Certificate of Foreign Intermediary, Foreign FlowThrow Entity, or certain U.S. Branches for U.S. Tax Withholding (Form W-8IMY) applicable with respect
to U.S. equities.
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Flow 4. Non-Qualified Intermediaries (NQIs) and Flow-Through Entities (FTEs)
An NQI is a non-U.S. intermediary that does not become a QI owing to the fact that it has not signed QIA
with the IRS.
An FTE is:
• Foreign partnership;
• Foreign Simple Trust, Complex Trust or Grantor Trust;
• Any other entity that is considered fiscally transparent.
An exemption or relief at source from withholding tax and backup withholding tax is available to an NQI.
Claims for refund of withholding tax and backup withholding tax from the IRS are not available through
Clearstream Banking.
To claim NQI status, the customer must submit a Certificate of Foreign Intermediary, Foreign FlowThrow Entity, or certain U.S. Branches for U.S. Tax Withholding (Form W-8IMY) applicable with respect
to U.S. equities.
Reclaim of withholding tax from Clearstream Banking
In certain cases, customers can reclaim U.S. withholding tax through Clearstream Banking, as
explained in “Reclaiming withholding tax from Clearstream Banking” on page 56.
Note: Customers are urged to monitor their accounts in order to minimise the number of reclaim
requests.
Refund from the IRS
As mentioned earlier, the claim for refund of withholding tax or backup withholding tax from the IRS is
not available through Clearstream Banking.
However, customers may apply directly through the IRS. The statutory deadline for claiming a refund of
withholding tax is three years from the time that the return was filed or two years from the time that the
tax was paid, whichever of such periods expires later. If no tax return was filed, the deadline for
claiming a refund of withholding tax the through IRS is two years from the time that the tax was paid.
Details on the refund procedures can be found on the IRS web site: www.irs.gov.
In order to support its customers, Clearstream Banking will provide the following documentation upon
request from the customer:
• A letter including general information on the procedure;
• A payment advice with details of the income payment and tax withheld;
• A copy of Form 1042-S (if a copy is requested by the customer).
Customer requests should be sent, by an authenticated means of communication, to the attention of
OTL - Tax Services. The following information must be included in the request:
• Account number;
• Security code and description;
• Payment date;
• Total holding;
• Name and address of the person to whom the documents should be mailed;
• Gross amount /net amount / tax amount.
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Obtaining relief at source from withholding tax
Relief at source - Who can obtain relief at source?
Beneficial owners can obtain an exemption at source or relief at source from withholding tax on
dividends, as follows:
Rate applicable
at source
Eligible Beneficial Owners
Foreign persons and/or residents of a DTT country
0% or DTT rate or 30%,
whichever is lower
See...
Appendix 2 on
page A-5
Foreign governments and other foreign organisations
0%
-
Foreign persons whose income is effectively connected
with the conduct of a trade or business in the U.S.A.
0%
-
U.S. persons
0%
-
Qualified Intermediaries
0% or DTT rate or 30%,
whichever is lower
Appendix 2 on
page A-5
Non-Qualified Intermediaries and Flow-Through
Entities
0% or DTT rate or 30%,
whichever is lower
Appendix 2 on
page A-5
Relief at source - What documents are required?
There are different documentation requirements depending on whether the customer is:
• A foreign person and/or resident of a DTT country; or
• A foreign government or other foreign organisation; or
• A foreign person whose income is effectively connected with the conduct of a trade or business in
the U.S.A.; or
• A U.S. person; or
• A Qualified Intermediary; or
• A Non-Qualified Intermediary or a Flow-Through Entity.
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The documents to be completed and submitted to Clearstream Banking in order to obtain exemption at
source or relief at source are described in more detail in the following tables.
Document
See...
If the customer is a foreign person and/or a resident of a DTT country, this documentation must be
used:
Form W-8BEN: Certification of Foreign Status of Beneficial Owner
for U.S. Tax Withholding (Form W-8BEN with part II completed if
the customer is resident in a DTT country and claims DTT relief on
dividends)
Appendix 4 on page A-14
(information purposes only)
Certification that provides certain statements regarding the beneficial owner of the securities.
Note: IRS Form W-8BEN with detailed instructions can be obtained from the IRS web site:
http://www.irs.gov/app/picklist/list/formsInstructions.html.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8BEN and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
By the first dividend payment, thereafter renewal upon expiry. In the event
of changes, a new form must be provided to Clearstream Banking within 30
days. The form is valid from the date of the signature until the end of the
third succeeding calendar year.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
dividend payment by 10:00 CET.
Copy or original?
Original required.
Withholding Statement - Non-U.S. beneficial owners
Appendix 9 on page A-24
One time certification that provides additional payment information.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8BEN and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
Once. Valid until revoked by the customer. In the event of changes, a new
Withholding Statement must be provided to Clearstream Banking within 30
days.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
dividend payment by 10:00 CET.
Copy or original?
Original required.
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Document
See...
If the customer is a foreign government or other foreign organisation, this documentation must be
used:
Form W-8EXP: Certificate of Foreign Government or other Foreign
Organisation for U.S. Tax Withholding
Appendix 5 on page A-15
(information purposes only)
Certification that qualifies the customer that is a foreign government or other foreign organisation for
an exemption.
Note: IRS Form W-8EXP with detailed instructions can be obtained from the IRS web site:
http://www.irs.gov/app/picklist/list/formsInstructions.html.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8EXP and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
By the first dividend payment, thereafter renewal upon expiry. In the event
of changes, a new W-8EXP must be provided to Clearstream Banking
within 30 days. The form is valid from the date of the signature until the
end of the third succeeding calendar year.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
dividend payment by 10:00 CET.
Copy or original?
Original required.
Withholding Statement - Non-U.S. beneficial owners
Appendix 9 on page A-24
One time certification that provides additional payment information.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8EXP and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
Once. Valid until revoked by the customer. In the event of changes, a new
Withholding Statement must be provided to Clearstream Banking within 30
days.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
dividend payment by 10:00 CET.
Copy or original?
Original required.
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See...
If the customer is a beneficial owner whose income is effectively connected with the conduct of a
trade or business in the U.S.A., this documentation must be used:
Form W-8ECI: Certification of Foreign Person's Claim for Exemption
from Withholding on Income Effectively Connected with the conduct of
a Trade or Business in the U.S.A.
Appendix 6 on page A-17
(information purposes only)
Certification that qualifies the eligible recipient as a beneficial owner whose income is effectively
connected with the conduct of a trade or business in the U.S.A.
Note: IRS Form W-8ECI with detailed instructions can be obtained from the IRS web site:
http://www.irs.gov/app/picklist/list/formsInstructions.html.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8ECI and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
By the first dividend payment, thereafter renewal upon expiry. In the event
of changes, a new W-8ECI must be provided to Clearstream Banking within
30 days. The form is valid from the date of the signature until the end of the
third succeeding calendar year.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
dividend payment by 10:00 CET.
Copy or original?
Original required.
Withholding Statement - Non-U.S. beneficial owners
Appendix 9 on page A-24
One time certification that provides additional payment information.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8ECI and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
Once. Valid until revoked by the customer. In the event of changes, a new
Withholding Statement must be provided to Clearstream Banking within 30
days.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
dividend payment by 10:00 CET.
Copy or original?
Original required.
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Document
See...
If the customer is a U.S. person, this documentation must be used:
Form W-9: Request for Taxpayer Identification Number and
Certification
Appendix 8 on page A-20
(information purposes only)
One time certification, the purpose of which is to provide the correct Taxpayer Identification Number
(TIN), to certify that the person is not subject to backup withholding tax or to claim exemption from
backup withholding tax by a U.S. exempt person.
Note: IRS Form W-9 with detailed instructions can be obtained from the IRS web site:
http://www.irs.gov/app/picklist/list/formsInstructions.html.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-9 and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
Once. Valid until revoked by the customer. In the event of changes, a new
W-9 must be provided to Clearstream Banking within 30 days.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
dividend payment by 10:00 CET.
Copy or original?
Original required.
Withholding Statement - U.S. person
Appendix 10 on page A-27
One time certification that provides additional payment information.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-9 and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
Once. Valid until revoked by the customer. In the event of changes, a new
Withholding Statement must be provided to Clearstream Banking within 30
days.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
dividend payment by 10:00 CET.
Copy or original?
Original required.
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See...
If the customer is a Qualified Intermediary type A, this documentation must be used:
Form W-8IMY: Certificate of Foreign Intermediary, Foreign FlowThrough Entity, or Certain U.S. Branches for U.S. Tax Withholding
Appendix 7 on page A-18
(information purposes only)
Certification that qualifies the eligible recipient as a QI.
Note: IRS Form W-8IMY with detailed instructions can be obtained from the IRS web site:
http://www.irs.gov/app/picklist/list/formsInstructions.html.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8IMY and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
By the first dividend payment, renewal upon expiry. In the event of changes,
a new W-8IMY must be provided to Clearstream Banking within 30 days.
The form is valid from the date of the signature until the end of the third
succeeding calendar year, unless the QI-EIN is completed, in which case
the W-8IMY is valid until revoked by the customer.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
dividend payment by 10:00 CET.
Copy or original?
Original required.
Withholding Statement QI - A Account
Appendix 11 on page A-29
Withholding Statement QI - A Account is a one-time certification of a QI that has assumed primary
NRA withholding responsibility and backup withholding and 1099 reporting responsibility with
respect to all U.S. securities held in the account.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8IMY and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
Once. Valid until revoked by the customer. In the event of changes, a new
Withholding Statement must be provided to Clearstream Banking within 30
days.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
income payment by 10:00 CET.
Copy or original?
Original required.
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See...
If the customer is a Qualified Intermediary type B, this documentation must be used:
Form W-8IMY: Certificate of Foreign Intermediary, Foreign FlowThrough Entity, or Certain U.S. Branches for U.S. Tax Withholding
Appendix 7 on page A-18
(information purposes only)
Certification that qualifies the eligible recipient as a QI.
Note: IRS Form W-8IMY with detailed instructions can be obtained from the IRS web site:
http://www.irs.gov/app/picklist/list/formsInstructions.html.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8IMY and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
By the first dividend payment, renewal upon expiry. In the event of changes,
a new W-8IMY must be provided to Clearstream Banking within 30 days.
The form is valid from the date of the signature until the end of the third
succeeding calendar year, unless the QI-EIN is completed, in which case
the W-8IMY is valid until revoked by the customer.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
dividend payment by 10:00 CET.
Copy or original?
Original required.
Withholding Statement QI - B Account
Appendix 12 on page A-32
Withholding Statement QI - B Account is a one-time certification of a QI that has assumed primary
NRA withholding responsibility and has not assumed backup withholding and 1099 reporting
responsibility with respect to all U.S. securities held in the account.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8IMY and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
Once. Valid until revoked by the customer. In the event of changes, a new
Withholding Statement must be provided to Clearstream Banking within 30
days.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
dividend payment by 10:00 CET.
Copy or original?
Original required.
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Document (cont’d)
See...
If the customer is a Qualified Intermediary type B, this documentation must be used: (cont’d)
Form W-9: Request for Taxpayer Identification Number and
Certification
Appendix 8 on page A-20
(information purposes only)
Applicable only to QI type B customers who hold U.S. securities on behalf of U.S. non-exempt persons.
One-time certification, the purpose of which is to provide the correct Taxpayer Identification Number
(TIN) of the U.S. non-exempt person.
Note: IRS Form W-9 with detailed instructions can be obtained from the IRS web site:
http://www.irs.gov/app/picklist/list/formsInstructions.html.
How many are provided?
Per U.S. non-exempt person.
Who completes it?
U.S. non-exempt person.
How often is it provided?
Once. Valid until revoked. In the event of changes, a new W-9 must be
provided to Clearstream Banking within 30 days.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
dividend payment by 10:00 CET.
Copy or original?
Original required.
Allocation Information
-
Provides certain statements regarding the allocation of the payment to the underlying beneficial
owners of the securities.
QI type B customers that have an omnibus account for U.S. non-exempt persons are required to
provide a Form W-9 from each U.S. non-exempt person and allocation information per dividend
payment. The allocation information must include the following details:
Account number; Security code and description; Payment date; Total holding; Breakdown per
U.S. non-exempt person.
How many are provided?
Per Clearstream Banking account or specified set of Clearstream Banking
accounts.
Who completes it?
Customer.
How often is it provided?
Prior to each dividend payment.
When is it provided?
The customer must submit the completed form to Clearstream Banking at
least two business days prior to the relevant dividend payment by 10:00
CET.
Copy or original?
Allocation information must be submitted via SWIFT or CreationOnline.
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See...
If the customer is a Qualified Intermediary type C, this documentation must be used:
Form W-8IMY: Certificate of Foreign Intermediary, Foreign FlowThrough Entity, or Certain U.S. Branches for U.S. Tax Withholding
Appendix 7 on page A-18
(information purposes only)
Certification that qualifies the eligible recipient as a QI.
Note: IRS Form W-8IMY with detailed instructions can be obtained from the IRS web site:
http://www.irs.gov/app/picklist/list/formsInstructions.html.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8IMY and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
By the first dividend payment, renewal upon expiry. In the event of changes,
a new W-8IMY must be provided to Clearstream Banking within 30 days.
The form is valid from the date of the signature until the end of the third
succeeding calendar year, unless the QI-EIN is completed, in which case
the W-8IMY is valid until revoked by the customer.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
dividend payment by 10:00 CET.
Copy or original?
Original required.
Withholding Statement QI - C Account
Appendix 13 on page A-35
Withholding Statement QI - C Account is a one-time certification of a QI that has not assumed primary
NRA withholding responsibility and has not assumed backup withholding and 1099 reporting
responsibility with respect to all U.S. securities held in the account.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8IMY and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
Once. Valid until revoked by the customer. In the event of changes, a new
Withholding Statement must be provided to Clearstream Banking within 30
days.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
dividend payment by 10:00 CET.
Copy or original?
Original required.
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Document (cont’d)
See...
If the customer is a Qualified Intermediary type C, this documentation must be used: (cont’d)
Form W-9: Request for Taxpayer Identification Number and
Certification
Appendix 8 on page A-20
(information purposes only)
Applicable only to QI type C customers who hold U.S. securities on behalf of U.S. non-exempt persons.
One-time certification, the purpose of which is to provide the correct Taxpayer Identification Number
(TIN) of the U.S. non-exempt person.
Note: IRS Form W-9 with detailed instructions can be obtained from the IRS web site:
http://www.irs.gov/app/picklist/list/formsInstructions.html.
How many are provided?
Per U.S. non-exempt person.
Who completes it?
U.S. non-exempt person.
How often is it provided?
Once. Valid until revoked. In the event of changes, a new W-9 must be
provided to Clearstream Banking within 30 days.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
dividend payment by 10:00 CET.
Copy or original?
Original required.
Allocation Information
-
Provides certain statements regarding the allocation of the payment to the underlying beneficial
owners of the securities.
• QI type C customers that have an omnibus account for non-U.S. beneficial owners and U.S.
exempt persons are required to provide allocation information per dividend payment in order to
be entitled to relief or exemption from U.S. withholding tax. The allocation information must
include the following details:
Account number; Security code and description; Payment date; Total holding; Withholding
tax rates to be applied per holding.
• QI type C customers that have an omnibus account for U.S. non-exempt persons are required
to provide a Form W-9 from each U.S. non-exempt person and allocation information per
dividend payment. The allocation information must include the following details:
Account number; Security code and description; Payment date; Total holding; Breakdown
per U.S. non-exempt person.
How many are provided?
Per Clearstream Banking account or specified set of Clearstream Banking
accounts.
Who completes it?
Customer.
How often is it provided?
Prior to each dividend payment.
When is it provided?
The customer must submit the completed form to Clearstream Banking at
least two business days prior to the relevant dividend payment by 10:00
CET.
Copy or original?
Allocation information must be submitted via SWIFT or CreationOnline.
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See...
If the customer is a Non-Qualified Intermediary or a Flow-Through Entity, this documentation must
be used:
Form W-8IMY: Certificate of Foreign Intermediary, Foreign FlowThrough Entity, or Certain U.S. Branches for U.S. Tax Withholding
Appendix 7 on page A-18
(information purposes only)
Certification that qualifies the eligible recipient as a NQI or a Flow-Through Entity.
Note: IRS Form W-8IMY with detailed instructions can be obtained from the IRS web site:
http://www.irs.gov/app/picklist/list/formsInstructions.html.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8IMY and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
By the first dividend payment, renewal upon expiry. In the event of changes,
a new W-8IMY must be provided to Clearstream Banking within 30 days.
The form is valid from the date of the signature until the end of the third
succeeding calendar year.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the
relevant dividend payment by 10:00 CET.
Copy or original?
Original required.
Withholding Statement - NQI account
Appendix 14 on page A-39
One time certification that provides additional payment information.
How many are provided?
Per Clearstream Banking account, up to four accounts. For five and/or
more Clearstream Banking accounts, the customer must provide a
covering letter listing the accounts, in addition to the W-8IMY and the
Withholding Statement.
Who completes it?
Customer.
How often is it provided?
Once. Valid until revoked by the customer. In the event of changes, a new
Withholding Statement must be provided to Clearstream Banking within 30
days.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the
relevant dividend payment by 10:00 CET.
Copy or original?
Original required.
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See...
If the customer is a Non-Qualified Intermediary or a Flow-Through Entity, this documentation must
be used: (cont’d)
Form W-8BEN, W-8EXP, W-8ECI, W-8IMY, W-9
Appendix 8 on page A-20
Appendix 4 on page A-14
Appendix 5 on page A-15
Appendix 6 on page A-17
Appendix 7 on page A-18
(information purposes only)
If the NQI has an account structure containing one of the following:
• One account for each U.S. non-exempt person;
• One account for all U.S. exempt persons;
• One account for each non-U.S. beneficial owner;
• One account for each QI withholding and reporting pool;
• One account for each underlying NQI with a single beneficial owner.
the customer must supply the following documentation in addition to the above-stated form W-8IMY.
Note: The IRS Forms W-9, W-8BEN, W-8EXP, W-8ECI or W-8IMY with their respective detailed
instructions can be obtained from the IRS web site:
http://www.irs.gov/app/picklist/list/formsInstructions.html.
How many are provided?
One Form W-8BEN, W-8EXP or W-8ECI from each non-U.S. beneficial
owner;
One Form W-8IMY from each QI or NQI;
One Form W-9 from each U.S. non-exempt and U.S. exempt person.
Who completes it?
Forms W-8BEN, W-8EXP or W-8ECI: Beneficial owner.
Form W-8IMY: Underlying QI or NQI;
Form W-9: U.S. non-exempt, U.S. exempt person.
How often is it provided?
By the first income payment, thereafter renewal upon expiry. In the event
of changes, a new form must be provided to Clearstream Banking within 30
days.
W-9 is valid until revoked, forms W-8xxx are valid from the date of the
signature until the end of the third succeeding calendar year.
When is it provided?
The customer must submit the completed form to Clearstream Banking
upon opening the account(s) or at least two business days before the first
dividend payment by 10:00 CET.
Copy or original?
Original required.
Relief at source - When is the deadline for receipt of documents?
Documentation must be received by Clearstream Banking by the following dates:
Document
Deadline for receipt by Clearstream Banking
W-8BEN, W-8EXP, W-8ECI, W-8IMY, W-9
Two business days prior to first dividend payment by 10:00 CET.
Withholding Statement
Two business days prior to first dividend payment by 10:00 CET.
Allocation Information
Two business days prior to the relevant dividend payment by 10:00 CET.
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Reclaiming withholding tax from Clearstream Banking
Tax reclaim - Who can reclaim withholding tax?
Recipients can reclaim withholding tax on dividends from Clearstream Banking as follows:
Eligible Recipients
Qualified Intermediaries
Effective rate of tax
after refund a
Tax refund
available a
0% or DTT treaty rate
or 30%, whichever is lower
30% or 30% minus
the DTT rate b
See...
Appendix 2 on
page A-5
a. Expressed as a percentage of the gross dividend amount.
b. Amount of relief will be 0% if the DTT rate exceeds 30%.
Tax reclaim - In which cases may Clearstream Banking accept reclaims?
Customers may be eligible to reclaim U.S. withholding tax through Clearstream Banking in the
following circumstances:
• The customer has not received pre-notification of a payment.
If, for example, the payment is not included in the Income Pre-Advice Report, the customer will
be entitled to an automatic adjustment of tax over-withheld without having to submit the reclaim
form. If the customer has been notified of payments by Clearstream Banking, a reclaim form
must be submitted in order to be eligible to reclaim U.S. withholding tax.
• The customer has not provided the required allocation information.
If a customer fails to supply the required allocation information for a payment within the
Clearstream Banking deadline (two days before the income payment date), the customer must
both submit a completed reclaim form and send the required allocation information to
Clearstream Banking before the end of the calendar year in which the payment was made. After
this period, Clearstream Banking will not accept reclaims and the customer will have to request
a refund directly from the IRS.
• The customer does not hold the securities in a certified account.
If, for example, the customer transferred securities between accounts for netting purposes but
did not allocate the securities to a certified account on a record date, the customer may reclaim
the tax over-withheld. Clearstream Banking will apply the appropriate withholding tax to the
account where the securities were held on record date in accordance with the documentation in
place for the account.
Tax reclaim - What documents are required?
The documents to be completed and submitted to Clearstream Banking in order to reclaim withholding
tax on dividends from Clearstream Banking, are described in more details in the following tables.
Document
See...
Statement to Reclaim U.S. Withholding Tax
Appendix 16 on page A-46
Clearstream Banking's reclaim form identifying the status of the customer and the reason for reclaim
and including security and payment details, as well as the applicable tax rates.
Who completes it?
Customer.
How often is it provided?
Per reclaim application.
When is it provided?
Before the end of the calendar year in which the payment was made.
Copy or original?
Original required.
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Allocation Information
-
Provides certain statements regarding the allocation of the payment to the underling beneficial
owners of the securities. QI type B and C customers that have an omnibus account for non-U.S.
beneficial owners and U.S. exempt persons but who failed to supply the required allocation
information for a payment within the Clearstream Banking deadline (two days before the income
payment date) must provide allocation information per reclaim application.
The allocation information must include the following details:
Account number; Security code and description; Payment date; Total holding; Withholding tax
rates to be applied per holding.
Who completes it?
Customer (QI type B or C) with an omnibus account.
How often is it provided?
Per reclaim application.
When is it provided?
Before the end of the calendar year in which the payment was made.
Copy or original?
Allocation information must be submitted via SWIFT or CreationOnline.
Tax reclaim - When is the deadline for receipt of documents?
Documentation must be received by Clearstream Banking by the following dates:
Document
Deadline for receipt by Clearstream Banking
Statement to Reclaim U.S.
Withholding Tax
Before the end of the calendar year in which the payment was made.
Allocation Information
Before the end of the calendar year in which the payment was made.
Tax reclaim - How are reimbursements effected?
The QI Agreement with the IRS allows Clearstream Banking to adjust over-withheld tax either by setting
it off against subsequent withholding (“set off”) or by reimbursement.
Clearstream Banking makes weekly deposits via the Electronic Federal Tax Payment System (EFTPS)
such that, at the precise time that the customer submits a valid reclaim request, there may not be
sufficient funds in Clearstream Banking’s tax account to make a reimbursement.
Clearstream Banking processes reimbursements in the order received and only at such time as funds
in the tax account are sufficient. If a reimbursement could not be made before the end of the calendar
year due to insufficient funds in the tax acount, customers must apply for a refund directly fro the IRS.
All reimbursements are made by Clearstream Banking in U.S. Dollars (USD). For income payments
made in a currency other than USD, the tax amount to be reimbursed is converted into USD at the
foreign exchange rate prevailing at the time of the withholding.
Reporting of withholding tax and backup withholding tax
Information reporting obligations
Reporting is the obligation to provide information to the IRS on the amount of income that the
withholding agent has received from its payers and paid to its customers.
There are two different IRS reporting forms:
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Form 1042-S: Foreign Person's U.S. Source Income Subject to
Withholding
Appendix 17 on page A-48
(information purposes only)
Form 1042-S, Foreign Person's U.S. Source Income Subject to Withholding, must be filed on or before
15 March of the year following the tax period calendar year in which the payment reported on the form
was made. Form 1042-S includes a copy to be sent to the IRS and copies to recipients.
Note: Copies of Form 1042-S with detailed instructions can be obtained from the IRS web site:
http://www.irs.gov/app/picklist/list/formsInstructions.html.
Depending on the customer's QI status, Clearstream Banking will issue the reports as follows:
• Reporting payments to customers who are direct beneficial owners
Payments that are made by Clearstream Banking directly to non-U.S. beneficial owners are
generally required to be reported on the basis of reporting pools. A reporting pool consists of
income with the same income code, exemption code and recipient code as defined by the
1042-S instructions.
• Reporting payments to QI customers
Clearstream Banking must complete a separate Form 1042-S for each withholding rate pool of
a QI. A withholding rate pool consists of income with the same income code and the same rate
of withholding.
• Reporting payments to NQI customers
Clearstream Banking must complete a Form 1042-S for each recipient of a payment from an
NQI or FTE. If Clearstream Banking lacks any information such as the name, address or income
allocation of the recipient, “unknown recipient” will be entered as the recipient.
Clearstream Banking reports payments to undocumented customers as an NQI. Please refer to
“Presumption Rules” on page 39.
Form 1099: U.S. Person's U.S. Source Income Subject to Withholding
Appendix 18 on page A-52
Appendix 19 on page A-55
(information purposes only)
Form 1099, the specific version of which depends on type of income (for example, 1099-DIV for
dividends, 1099-INT for interest income, 1099-OID for original issue discount and 1099-B for broker
proceeds) has multiple copies, three of which are to be sent to the recipient and one to the IRS.
Form 1099 must be filed by:
• 31 January of the year following the tax period calendar year in which the payment reported on
the form was made, if filed on paper. The forms must be filed with both the recipients and the
IRS;
• 28 February of the same year if filed on magnetic media. The forms must be filed with the IRS
only; or
• 1 April of the same year if filed electronically. The forms must be filed with the IRS only.
Filing by means of magnetic or electronic media is required if 250 or more forms are to be filed. If
Clearstream Banking lacks the name and address of a recipient who is a U.S. non-exempt person,
“unknown recipient” will be entered as the recipient.
Note: Form 1099 with detailed instructions can be obtained from the IRS web site:
http://www.irs.gov/app/picklist/list/formsInstructions.html.
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Details of the reporting to be issued by Clearstream Banking and the reporting to be issued by
customers are in the following table:
Customer status
IRS reporting issued by Clearstream Banking
IRS reporting issued by the customer
U.S. Person not acting as QI through a non-U.S. branch
No reporting
Reporting as required of U.S. Withholding Agent
Non-U.S. beneficial oOwner
One 1042-S for all beneficial owners that are direct account holders, per income type, per tax rate
and per exemption code
QI-A
One 1042-S per income type to the customer
• One 1042-S for:
- All beneficial owners that are direct account holders per income type, per tax
rate and per exemption code;
- Each customer that is QI or NQI that has not disclosed beneficial owners, per
income type, per tax rate (and per exemption code);
- Each beneficial owner if customer is NQI, per income type, per tax rate;
• One 1099 to all U.S. non-exempt persons per income type to each U.S. nonexempt person and presumed U.S. non-exempt person if backup withholding
applied.
QI-B:
Omnibus account for all non U.S. account holders and U.S. exempt persons
One 1042-S per income type to the customer
1042-S reporting as indicated under QI-A
Omnibus account for U.S. non-exempt person
One 1099 per income type to each U.S. non-exempt person
Customer may have to issue additional 1099 reporting
Segregated accounts per U.S. non-exempt person
One 1099 per income type to each U.S. non-exempt person
Customer may have to issue additional 1099 reporting
QI-C:
Omnibus account for all non-U.S. account holders and U.S. exempt persons
One 1042-S to the customer per income type and per tax rate
1042-S reporting as indicated under QI-A
Segregated accounts per DTT rate for beneficial owners for whom DTT relief is claimed
One 1042-S to customer per income type
Segregated accounts for non-U.S. beneficial owners for whom no relief on dividends is claimed but exemption on
interest and OID is claimed
One 1042-S to customer per income type
-
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Customer status
IRS reporting issued by Clearstream Banking
IRS reporting issued by the customer
Segregated accounts for documented non-U.S. beneficial owners for whom no relief is claimed on dividends or
interest or long-term OID
One 1042-S to customer per income type
Segregated accounts for undocumented beneficial owners not presumed to be U.S. non-exempt persons
• One 1042-S to customer per income type
• One 1099 to customer per income type if backup withholding applied
Segregated accounts for U.S. exempt persons, U.S. branches with Effectively Connected Income, non-U.S. taxexempt foreign governments, international organisations and charities
One 1042-S to customer per income type
Omnibus accounts for U.S. non-exempt persons
One 1099 per income type to each U.S. non-exempt person
Customer may have to issue additional 1099 reporting
Segregated accounts per U.S. non-exempt person
One 1099 per income type to each U.S. non-exempt person
Customer may have to issue additional 1099 reporting
NQI or FTE:
Segregated accounts per U.S. non-exempt person
One 1099 per income type to each U.S. non-exempt person
Segregated accounts per non-U.S. beneficial owner for whom tax relief is requested
One 1042-S per income type to each beneficial owner
Segregated accounts per documented non-U.S. beneficial owner for whom no tax relief is requested
One 1042-S per income type to each Beneficial Owner
Segregated accounts per QI withholding and reporting pool
One 1042-S per income type and per withholding and reporting pool to QI
Segregated accounts per underlying NQI with a single non-U.S. beneficial owner
One 1042-S per income type to the beneficial owner
Segregated accounts per underlying NQI with a single U.S. non-exempt person
One 1099 per income type to the beneficial owner
-
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Receipt of reports
Clearstream Banking will supply 1042-S and 1099 reports by customer and by beneficial owner.
Clearstream Banking customers may indicate whether they require Clearstream Banking to send the
reports directly to their underlying customers or to receive them directly themselves for onward
distribution to their underlying customers. In cases where Clearstream Banking customers want to
receive reports directly for onward distribution to their customers, they must sign a waiver to this effect
(see Appendix 20 on page A-58).
Voiding and correcting forms with errors
If a person who files Form(s) 1042-S and/or Form(s) 1099 with the IRS discovers later that an error has
been made on the form, the reporting must be corrected as soon as possible. To correct a previously
filed Form 1042-S and/or Form 1099, two Forms 1042-S and/or Forms 1099 need to be filed:
• One with the “VOID” box ticked showing the same information, including the error or errors, as in
the form previously filed with the IRS;
• A second with the “CORRECTED” box ticked and containing the correct reporting.
If any information corrected in Form(s) 1042-S and/or Form(s) 1099 changes the information previously
reported on Form 1042 and/or Form 945, these forms must also be corrected by filing an amended
return.
Late filing of a corrected Form 1042-S and/or Form 1099 with the IRS and failure to furnish a corrected
Form 1042-S and/or Form 1099 to the recipient will result in penalties.
Tax return obligations
Customers may be required to submit to the IRS the following:
•
IRS Form 945 “Annual Return of Withheld Federal Income Tax”
The 1099 report issued by Clearstream Banking or other withholding agent must be attached.
The forms must be filed with the IRS by 31 January of the year following the tax period calendar
year in which the payment reported on the form was made.
And/or:
•
IRS Form 1042 “Annual Withholding Tax Return for U.S. Source Income of Foreign Persons”
The 1042-S report issued by Clearstream Banking or other withholding agent must be attached.
The forms must be filed with the IRS by 15 March of the year following the tax period calendar
year in which the payment reported on the form was made.
IRS Forms 945 and 1042 with detailed instructions can be obtained from the IRS web site:
http://www.irs.gov/app/picklist/list/formsInstructions.html. Appendix 21 on page A-59 and Appendix 22
on page A-61 are provided for information purposes only.
Tax Calendars
A tax calendar is a 12-month calendar divided into quarters. The calendar gives specific due dates for
the following:
• Filing tax forms;
• Paying taxes; and
• Taking other actions required by federal tax law.
The current tax calendar together with the instructions can be found on the IRS web site:
http://www.irs.gov/pub/irs-pdf/p509.pdf.
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A. Appendices
Tip: An easy way of writing the letters required for an application is to copy them from the appendices
using Acrobat Reader, then edit and print them. To copy the text of any example letters using your
Acrobat Reader, obtain the text cursor using the ABC icon or the Tools-Select Text command, drag
across the required text, then select Edit-Copy. In your own word processing package, you can then
paste the text (this pastes the copied characters, but does not hold the formatting), complete the letter,
and print it on your own letterhead.
Important note: The IRS Forms listed below are subject to changes. Therefore, the appendices
containing these forms are for information purposes only.
All the IRS Forms with their respective detailed instructions must be obtained from the IRS web site:
http://www.irs.gov/app/picklist/list/formsInstructions.html.
General:
Appendix 1. Debt securities - Double Taxation Treaties concluded by the U.S.A and currently in force
Appendix 2. Equities - Double Taxation Treaties concluded by the U.S.A and currently in force
Appendix 3. Account types and structures in Clearstream Banking for U.S. withholding tax purposes
For relief at source:
Appendix 4. IRS Form W-8BEN (Certification of Foreign Status of Beneficial Owner for U.S. Tax
Withholding)
Appendix 5. IRS Form W-8EXP (Certificate of Foreign Government or other Foreign Organisation for
U.S. Tax Withholding)
Appendix 6. IRS Form W-8ECI (Certification of Foreign Person's Claim for Exemption from
Withholding on Income Effectively Connected with the conduct of a Trade or Business in
the U.S.)
Appendix 7. IRS Form W-8IMY (Certificate of Foreign Intermediary, Foreign Flow-Through Entity, or
Certain U.S. Branches for U.S. Tax Withholding)
Appendix 8. IRS Form W-9 (Request for Taxpayer Identification Number and Certification)
Appendix 9. Withholding Statement - Non-U.S. Beneficial Owners
Appendix 10. Withholding Statement - U.S. Persons
Appendix 11. Withholding Statement - QI-A Account
Appendix 12. Withholding Statement - QI-B Account
Appendix 13. Withholding Statement - QI-C Account
Appendix 14. Withholding Statement - NQI Account
Appendix 15. U.S. Foreign Targeted Interest Certificate
For reclaiming withholding tax from Clearstream Banking
Appendix 16. Statement to Reclaim U.S. withholding tax
For a refund from the IRS:
N/A
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For reporting withholding tax and backup withholding tax1:
Appendix 17. IRS Form 1042-S (Foreign Person's U.S. Source Income Subject to Withholding) - 2008
Appendix 18. IRS Form 1099 INT (U.S. Person's U.S. Source Income Subject to Withholding) - 2008
Appendix 19. IRS Form 1099 - DIV (U.S. Person's U.S. Source Income Subject to Withholding - Dividend
Income) - 2008
Appendix 20. Customer Waiver Clause Letter
For tax return obligations1:
Appendix 21. IRS Form 945 (Annual Return of Withheld Federal Income Tax)
Appendix 22. IRS Form 1042 (Annual Withholding Tax Return for U.S. Source Income of Foreign
Persons) - 2008
1. These IRS Forms are 2008 versions. These forms are published on an annual basis and are generally issued mid-year by the IRS.
March 2013
A-2
Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 1. Debt securities - Double Taxation Treaties concluded by the
U.S.A and currently in force
Note: Clearstream Banking provides these rates for information purposes only and does not assume
liability in any case of error, omission or consequential damages. The rate as prescribed in the
Double Taxation Treaty (DTT) may differ depending on the status of the beneficial owner. Please
refer to the actual DTT or your tax advisor for further information.
There is currently no prescribed form for tax refund available for use.
Country
(Sheet 1 of 2)
Rate prescribed
by the DTT –
Interest (%)
Tax refund
available (%)
Prescribed form for tax refund
The standard rate of withholding tax on interest is 30%a prior to any refund.
Armenia
Australia
Austria
Azerbaijan
Bangladesh
Barbados
Belarus
Belgium
Bulgaria
Canada
China c
Cyprus
Czech Republic
Denmark
Egypt
Estonia
Finland
France
Georgia
Germany
Greece
Hungary
Iceland
India
Indonesia
Ireland
Israel
Italy
Jamaica
Japan
Kazakhstan
Korea, Republic of
Kyrgyzstan
Latvia
Lithuania
Luxembourg
Malta
Mexico
0
10
0
0
10
5b
0
15
5
0
10
10 d
0
0
15
10
0
0
0
0
30 / 0 e
0
0
15
10
0
17.5
10
12.5
10
10
12
0
10
10
0
10
15 / 10 / 4.9 f
Clearstream Banking
Customer Tax Guide - United States of America
30
20
30
30
20
25
30
15
25
30
20
20
30
30
15
20
30
30
30
30
0 / 30
30
30
15
20
30
12.5
20
17.5
20
20
18
30
20
20
30
20
15 / 20 / 25.1
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
March 2013
A-3
United States of America - Appendices
Country
(Sheet 2 of 2)
Rate prescribed
by the DTT –
Interest (%)
Tax refund
available (%)
Prescribed form for tax refund
The standard rate of withholding tax on interest is 30%a prior to any refund.
Moldova
Morocco
Netherlands
New Zealand
Norway
Pakistan
Philippines
Poland
Portugal
Romania
Russia
Slovak Republic
Slovenia
South Africa
Spain
Sri Lanka
Sweden
Switzerland
Tajikistan
Thailand
Trinidad and Tobago
Tunisia
Turkey
Turkmenistan
Ukraine
United Kingdom
Uzbekistan
Venezuela
0
15
0
10
10
30
15
0
10
10
0
0
5
0
10
10
0
0
0
15 / 10 g
30
15
15
0
0
0
0
10 / 4.95 g
30
15
30
20
20
0
15
30
20
20
30
30
25
30
20
20
30
30
30
15 / 20
0
15
15
30
30
30
30
20 / 25.05
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
a. This rate applies to U.S. debt securities issued before 1984 only. Subsequent issues of U.S. debt securities are subject
to 0% withholding tax.
b. A 0% rate applies if the interest is paid in respect of bonds issued by the government and local authorities.
c. The China DTT does not apply to Hong Kong.
d. A 0% rate applies if the interest is paid to a bank or other financial institution.
e. The exemption does not apply if the recipient controls directly indirectly more than 50% of the voting power in the paying
corporation.
f. The 4.9% rate applies to interest paid on public traded securities. The 10% rate applies to interest paid by banks
including savings banks and investment banks. The 15% rate applies to other interest.
g. The lower rate applies if the interest is beneficially owned by any financial institutions (including an insurance
company).
March 2013
A-4
Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 2. Equities - Double Taxation Treaties concluded by the U.S.A
and currently in force
Note: Clearstream Banking provides these rates for information purposes only and does not assume
liability in any case of error, omission or consequential damages. The rate as prescribed in the
DTT assumes that the beneficial owner does not hold a substantial percentage of the share
capital of the company paying the dividend. Different rates may apply for substantial holdings.
Please refer to the actual DTT or your tax advisor for further information.
There is currently no prescribed form for tax refund available for use.
Country
(Sheet 1 of 2)
Rate prescribed
by the DTT –
Dividends (%)
Tax refund
available (%)
Prescribed form for tax refund
The standard rate of withholding tax on dividends is 30% prior to any refund.
Armenia
Australia
Austria
Azerbaijan
Bangladesh
Barbados
Belarus
Belgium
Bulgaria
Canada
China a
Cyprus
Czech Republic
Denmark
Egypt
Estonia
Finland
France
Georgia
Germany
Greece
Hungary
Iceland
India
Indonesia
Ireland
Israel
Italy
Jamaica
Japan
Kazakhstan
Korea, Republic of
Kyrgyzstan
Latvia
Lithuania
Luxembourg
Malta
Clearstream Banking
Customer Tax Guide - United States of America
30
15
15
30
15
15
30
15
10
15
10
15
15
15
15
15
15
15
30
15
30
15
15
25
15
15
25
15
15
10
15
15
30
15
15
15
15
0
15
15
0
15
15
0
15
20
15
20
15
15
15
15
15
15
15
0
15
0
15
15
5
15
15
5
15
15
20
15
15
0
15
15
15
15
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
March 2013
A-5
United States of America - Appendices
Country
(Sheet 2 of 2)
Rate prescribed
by the DTT –
Dividends (%)
Tax refund
available (%)
Prescribed form for tax refund
The standard rate of withholding tax on dividends is 30% prior to any refund.
Mexico
Moldova
Morocco
Netherlands
New Zealand
Norway
Pakistan
Philippines
Poland
Portugal
Romania
Russia
Slovak Republic
Slovenia
South Africa
Spain
Sri Lanka
Sweden
Switzerland
Tajikistan
Thailand
Trinidad and Tobago
Tunisia
Turkey
Turkmenistan
Ukraine
United Kingdom
Uzbekistan
Venezuela
10
30
15
15
15
15
30
25
15
15
10
10
15
15
15
15
15
15
15
30
15
25
20
20
30
15
15
30
15
20
0
15
15
15
15
0
5
15
15
20
20
15
15
15
15
15
15
15
0
15
5
10
10
0
15
15
0
15
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
a. The China DTT does not apply to Hong Kong.
March 2013
A-6
Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 3. Account types and structures in Clearstream Banking for U.S.
withholding tax purposes
1. Types of account
1. U.S. person
Accounts reserved for U.S. person exclusively not acting as a QI through a branch outside the U.S.A.
2. Non-U.S. beneficial owner
Accounts in which the Company will hold U.S. Securities exclusively for the account of the proprietary
business of non-U.S. beneficial owners.
3. QI 1099 and NRA omnibus accounts (A)1
Accounts reserved for QIs with primary NRA withholding responsibility and 1099 reporting and backup
withholding responsibility, in which the Company will hold U.S. Securities for any kind of recipient and
provide no allocation information to Clearstream Banking.
4. QI U.S. non-exempt omnibus accounts (B, C)
Accounts in which the Company will hold U.S. Securities as QI exclusively for the account of U.S. nonexempt recipients and provide allocation information to Clearstream Banking, without 1099 reporting and
without backup withholding responsibility.
5. QI U.S. non-exempt single beneficial owner accounts (B, C)
Accounts in which the Company will hold U.S. Securities as QI exclusively for the account of a single U.S.
non-exempt recipients, without 1099 reporting and without backup withholding responsibility.
6. QI Non-U.S. and U.S. exempt omnibus accounts (B, C)
Accounts in which the Company will hold U.S. Securities as QI exclusively for the account of persons other
than U.S. non-exempt recipients and will provide allocation information to Clearstream Banking prior to
each payment.
7. QI 15% treaty account (C)
Accounts in which the Company will hold U.S. Securities as QI exclusively for the account of non-U.S.
beneficial owners entitled to the following:
− Application of the 15% treaty rate with respect to dividends;
− Treaty exemption with respect to interest on bonds issued before 18 July 1984; and
− Portfolio interest exemption with respect to interest on bonds issued after 18 July 1984.
8. QI 10% treaty account (C)
Accounts in which the Company will hold U.S. Securities as QI exclusively for the account of non-U.S.
beneficial owners entitled to the following:
− Application of the 10% treaty rate with respect to dividends;
− Treaty exemption with respect to interest on bonds issued before 18 July 1984; and
− Portfolio interest exemption with respect to interest on bonds issued after 18 July 1984.
9. QI 20% treaty account (C)
Accounts in which the Company will hold U.S. Securities as QI exclusively for the account of non-U.S.
beneficial owners entitled to the following:
− Application of the 20% treaty rate with respect to dividends;
− Treaty exemption with respect to interest on bonds issued before 18 July 1984; and
− Portfolio interest exemption with respect to interest on bonds issued after 18 July 1984.
1. A, B and C are eligible types of intermediary for the associated account types.
Clearstream Banking
Customer Tax Guide - United States of America
March 2013
A-7
United States of America - Appendices
Appendix 3 (cont).
Account types and structures in Clearstream Banking for U.S.
withholding tax purposes
1. Types of account (cont)
10. QI 25% treaty account (C)
Accounts in which the Company will hold U.S. Securities as QI exclusively for the account of non-U.S.
beneficial owners entitled to the following:
− Application of the 25% treaty rate with respect to dividends;
− Treaty exemption with respect to interest on bonds issued before 18 July 1984; and
− Portfolio interest exemption with respect to interest on bonds issued after 18 July 1984.
11. QI 30% dividend 0% interest account (C)
Accounts in which the Company will hold U.S. Securities as QI exclusively for the account of non-U.S.
beneficial owners for whom the following apply:
− No tax relief is requested with respect to dividends.
− Treaty exemption with respect to interest on bonds issued before 18 July 1984; and
− Portfolio interest exemption with respect to interest on bonds issued after 18 July 1984.
12. QI exempt account (B, C)
Accounts in which the Company will hold U.S. Securities as QI exclusively for the account of:
− U.S. exempt recipients (for each of whom the QI provides Clearstream Banking with a Form W-9);
− Non-U.S. beneficial owners entitled to exemption on effectively connected income;
− Exempt foreign governments, international organisations and charities;
− Other QIs that assume primary NRA withholding responsibility; and/or
− Withholding foreign partnerships.
13. QI 30% documented non-U.S. account (C)
Accounts in which the Company will hold U.S. Securities as QI exclusively for the account of documented
non-U.S. beneficial owners for whom no tax relief is requested with respect to dividends or interest on
bonds issued before 18 July 1984, but for whom portfolio interest exemption is available with respect to
interest on bonds issued after 18 July 1984.
14. NQI U.S. non-exempt account
Accounts in which the Company will hold U.S. Securities as NQI exclusively for the account of a single U.S.
non-exempt recipient.
15. NQI 15% treaty account
Accounts in which the Company will hold U.S. Securities as NQI, exclusively for the account of:
− A single non-U.S. beneficial owner entitled to the following:
■
Application of the 15% treaty rate with respect to dividends;
■
Treaty exemption with respect to interest on bonds issued before 18 July 1984; and
■
Portfolio interest exemption with respect to interest on bonds issued after 18 July 1984.
or
− A QI holding the Securities exclusively for such beneficial owners.
March 2013
A-8
Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 3 (cont).
Account types and structures in Clearstream Banking for U.S.
withholding tax purposes
1. Types of account (cont)
16. NQI 10% treaty account
Accounts in which the Company will hold U.S. Securities as NQI, exclusively for the account of:
− A single non-U.S. beneficial owner entitled to the following:
■
Application of the 10% treaty rate with respect to dividends;
■
Treaty exemption with respect to interest on bonds issued before 18 July 1984; and
■
Portfolio interest exemption with respect to interest on bonds issued after 18 July 1984.
or
− A QI holding the Securities exclusively for such beneficial owners.
17. NQI 20% treaty account
Accounts in which the Company will hold U.S. Securities as NQI, exclusively for the account of:
− A single non-U.S. beneficial owner entitled to the following:
■
Application of the 20% treaty rate with respect to dividends;
■
Treaty exemption with respect to interest on bonds issued before 18 July 1984; and
■
Portfolio interest exemption with respect to interest on bonds issued after 18 July 1984.
or
− A QI holding the Securities exclusively for such beneficial owners.
18. NQI 25% treaty account
Accounts in which the Company will hold U.S. Securities as NQI, exclusively for the account of:
− A single non-U.S. beneficial owner entitled to the following:
■
Application of the 25% treaty rate with respect to dividends;
■
Treaty exemption with respect to interest on bonds issued before 18 July 1984; and
■
Portfolio interest exemption with respect to interest on bonds issued after 18 July 1984.
or
− A QI holding the Securities exclusively for such beneficial owners.
19. NQI 30% dividend 0% interest account
Accounts in which the Company will hold U.S. Securities as NQI, exclusively for the account of:
− A single non-U.S. beneficial owner for whom the following apply:
■
No tax relief is requested with respect to dividends.
■
Treaty exemption is requested with respect to interest on bonds issued before 18 July 1984; and
■
Portfolio interest exemption is requested with respect to interest on bonds issued after 18 July 1984.
or
− A QI holding the Securities exclusively for such beneficial owners.
Clearstream Banking
Customer Tax Guide - United States of America
March 2013
A-9
United States of America - Appendices
Appendix 3 (cont).
Account types and structures in Clearstream Banking for U.S.
withholding tax purposes
1. Types of account (cont)
20. NQI exempt account
Accounts in which the Company will hold U.S. Securities as NQI exclusively for the account of:
− U.S. exempt recipients (for each of whom the NQI provides Clearstream Banking with a Form W-9);
− A single non-U.S. beneficial owner entitled to exemption on effectively connected income;
− Exempt foreign governments, international organisations and charities;
− Other QIs that assume primary NRA withholding responsibility; and/or
− Withholding foreign partnerships;
or
− A QI holding the Securities exclusively for such beneficial owners.
21. NQI 30% documented non-U.S. account
Accounts in which the Company will hold U.S. Securities as NQI exclusively for the account of:
− A single documented non-U.S. beneficial owner that will be subject to 30% withholding tax on dividends
or interest on bonds issued before 18 July 1984, but for whom exemption is available with respect to
interest on bonds issued after 18 July 1984; or
− A QI holding the Securities exclusively for such beneficial owners.
March 2013
A - 10
Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 3 (cont).
Account types and structures in Clearstream Banking for U.S.
withholding tax purposes
2. Account structures
Note: The “**” column indicates the account type(s) (see “1. Types of account” on page A-7).
Customer's status
Options for account
structure with
Clearstream
Banking
Documentation from
underlying account
holders and
allocation information
to be provided to
Clearstream Banking
**
U.S. withholding
tax applied by
Clearstream
Banking
IRS reporting issued
by Clearstream
Banking
0%.
None.
IRS reporting to be
issued by customer
U.S. person not acting as QI through a branch outside the U.S.A.
Omnibus account
1
None.
Form W-9 completed by
Clearstream Banking’s
customer (with Withholding
Statement for the account)
is necessary and sufficient.
2
Not applicable.
Customer's Form W-8BEN,
W-8EXP or W8-ECI (with
Withholding Statement for
the account) is necessary
and sufficient.
Any reporting that may be
required of the customer
as U.S. withholding agent.
Non-U.S. beneficial owner
One or several accounts
as beneficial owner
Dividends: 0%, 30% or Included in one Form 1042-S
for all beneficial owners
DTT rate (usually 15%).
that are direct account
Interest on bonds issued:
holders, per income type,
- before 18.07.1984:
per tax rate and per
0%, 30% or DTT rate;
exemption code.
- after 18.07.1984: 0%.
QI (A): with primary NRA withholding responsibility and with 1099 reporting and backup withholding responsibility
Omnibus account for all
account holders
3
None.
Customer’s Form W-8IMY
(with Withholding Statement
for the account) is necessary
and sufficient.
0%.
One Form 1042-S per
income type to the
customer.
For non-U.S. account
holders, same as for QI
without primary NRA
withholding responsibility.
QI must issue one Form 1099
per income type to each
U.S. non-exempt recipient
and possibly additional
Forms 1099 reporting
other reportable payments.
QI (B): with Primary NRA withholding responsibility and without 1099 reporting and backup withholding responsibility
1.
For non-U.S. account holders and U.S. exempt recipients
Omnibus account for all
non-U.S. account
holders and U.S. exempt
recipients
6
None.
Customer's Form W-8IMY
(with Withholding Statement
for the account) is
necessary and sufficient.
0%.
One Form 1042-S per
income type to the
customer.
Same reporting as QI
without primary NRA
withholding responsibility.
& 2. For U.S. non-exempt recipients
2.1 Omnibus account for all
U.S. non-exempt
recipients
4
Customer’s Form W-8IMY
(with Withholding Statement
for the account) is necessary.
Form W-9 from each U.S.
non-exempt recipient
prior to payment.
Allocation information per
U.S. non-exempt recipient
prior to payment.
0%.
One Form 1099 per income
type to each U.S. nonexempt recipient.
Customer may have to
issue additional Form
1099 reporting other
reportable payments.
5
Form W-9 from each U.S.
non-exempt recipient
prior to payment.
No allocation information.
0%.
One Form 1099 per income
type to each U.S. nonexempt recipient.
Customer may have to
issue additional Form 1099
reporting other reportable
payments.
or
2.2 Separate account for
each U.S. non-exempt
recipient
Clearstream Banking
Customer Tax Guide - United States of America
March 2013
A - 11
United States of America - Appendices
Customer's status (cont’d)
Options for account
structure with
Clearstream
Banking
Documentation from
underlying account
holders and
allocation information
to be provided to
Clearstream Banking
**
U.S. withholding
tax applied by
Clearstream
Banking
IRS reporting issued
by Clearstream
Banking
IRS reporting to be
issued by customer
QI (C): without primary NRA withholding responsibility and without 1099 reporting and backup withholding responsibility
1.
For non-U.S. account holders and U.S. exempt recipients
1.1 Omnibus account for all
non-U.S. account
holders and U.S. exempt
recipients
6
No underlying
Dividends: 30% or DTT
documentation.
rate (usually 15%, can be
Customer’s Form W-8IMY
10%, 20%, 25%).
(with Withholding Statement Interest on bonds issued
for the account) is necessary.
before 18.07.1984:
Allocation information
30% or DTT rate.
per withholding rate
Exemption available for
before each payment.
interest on bonds issued
after 18.07.1984:
0% if documented;
30% otherwise.
One Form 1042-S
to the customer
per income type,
per tax rate.
or
1.2 Separate account per
7
None.
withholding rate pool for to
Customer’s Form W-8IMY
non-U.S. account
14 (with Withholding Statement
holders and U.S. exempt
for the account) is necessary.
recipients
One Form 1042S for each
beneficial owner if customer
is NQI, per income type,
per tax rate.
One account per dividend 7
DTT rate for beneficial
to
owners for whom DTT
10
relief is claimed on
dividends (usually 15%
but can be 10%, 20% or
25%)
Dividends: DTT rate
(usually 15%).
Interest on bonds issued
before 18.07.1984:
30% or DTT rate.
Exemption available for
interest on bonds issued
after 18.07.1984: 0%.
One Form 1042-S
to the customer
per income type.
One account for
11
documented non-U.S.
beneficial owners for
whom no relief is
claimed on dividends but
exemption is claimed on
interest and OID
Dividends: 30%.
Interest on bonds issued
before 18.07.1984:
30% or DTT rate.
Exemption available for
interest on bonds issued
after 18.07.1984: 0%.
One Form 1042-S
to the customer
per income type.
Dividends, interest and
long-term OID: 30%.
One Form 1042-S
to the customer
per income type.
0%.
One Form 1042-S
to the customer
per income type.
One account for
documented non-U.S.
beneficial owners for
whom no relief is
claimed on dividends,
interest and long-term
OID
13
One account for all U.S. 12
None.
exempt recipients, U.S.
Customer’s Form W-8IMY
branches with effectively
(with Withholding Statement
connected income, nonfor the account) is necessary.
U.S. tax exempt foreign
governments,
international
organisations and
charities
1. (1.1 and 1.2)
One Form 1042-S for all
beneficial owners that are
direct account holders, per
income type, per tax rate and
per exemption code.
One Form 1042-S for each
customer that is QI or NQI
that has not disclosed
beneficial owners, per
income type, per tax rate
(and per exemption code).
& 2. For U.S. non-exempt recipients
2.1 Omnibus account for all
U.S. non-exempt
recipients
4
Customer’s Form W-8IMY
(with Withholding Statement
for the account) is necessary.
Form W-9 from each U.S.
non-exempt recipient
prior to payment.
Allocation information per
U.S. non-exempt recipient
prior to payment.
0%.
One Form 1099
per income type
to each U.S. non-exempt
recipient.
5
Customer’s Form W-8IMY
(with Withholding Statement
for the account) is necessary.
Form W-9 from each U.S.
non-exempt recipient
prior to payment.
No allocation information.
0%.
One Form 1099
per income type
to each U.S. non-exempt
recipient.
or
2.2 Separate account for
each U.S. non-exempt
recipient
March 2013
A - 12
2. (2.1 and 2.2).
Customer may have
to issue additional Form
1099 reporting other
reportable payments.
Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Customer's status (cont’d)
Options for account
structure with
Clearstream
Banking
**
Documentation from
underlying account
holders and
allocation information
to be provided to
Clearstream Banking
U.S. withholding
tax applied by
Clearstream
Banking
IRS reporting issued
by Clearstream
Banking
IRS reporting to be
issued by customer
Non-QI
1.
14
Customer’s Form W-8IMY
(with Withholding Statement
for the account) is necessary.
Form W-9 from each U.S.
non-exempt recipient
prior to payment.
No allocation information.
0%.
One Form 1099
per income type
to each U.S. non-exempt
recipient.
& 2. One account for all U.S.
exempt recipients
20
Customer’s Form W-8IMY
(with Withholding Statement
for the account) is necessary.
Form W-9 from each U.S.
exempt recipient
prior to payment.
No allocation information.
0%.
None.
& 3. One account for each
non-U.S. beneficial
owner for whom tax
relief is requested
15 Customer’s Form W-8IMY
to (with Withholding Statement
20 for the account) is necessary.
Form W-8BEN, W-8EXP
or W-8ECI as appropriate
from each beneficial
owner prior to payment.
No allocation information.
Dividends: 0%, 30% or DTT
rate (usually 15%, can be
10%, 20%, 25%).
Interest on bonds issued
before 18.07.1984:
30% or DTT rate.
Exemption available for
interest on bonds issued
after 18.07.1984: 0%.
One Form 1042-S
per income type
to each beneficial owner.
& 4. One account per QI
withholding and
reporting pool, for each
QI for which the
customer is holding
Securities
15 Customer’s Form W-8IMY
to (with Withholding Statement
21 for the account) is necessary.
QI’s Form W-8IMY and
details of QI withholding
and reporting pool.
No allocation information.
Rates specified for the
relevant pool.
One Form 1042-S
per income type and
per withholding and
reporting pool, to the QI.
& 5. One account for each
(documented) non-U.S.
beneficial owner for
whom no tax relief is
requested
21
Dividends, interest and
long-term OID: 30%.
One Form 1042-S
per income type
to each beneficial owner.
& 6. One account for each
underlying NQI with a
single beneficial owner
14 Customer’s Form W-8IMY Dividends: 0%, 30% or DTT One Form 1042-S (or 1099)
per income type
to (with Withholding Statement rate (usually 15%, can be
to each beneficial owner.
21 for the account) is necessary.
10%, 20%, 25%).
Form W-8BEN, W-8EXP
Interest on bonds issued
or W-8ECI as appropriate
before 18.07.1984:
from each beneficial owner
30% or DTT rate.
prior to payment.
Exemption available for
No Allocation Information.
interest on bonds issued
after 18.07.1984: 0%
One account for each
U.S. non-exempt
recipient
Customer’s Form W-8IMY
(with Withholding Statement
for the account) is necessary.
Disclosure of beneficial
owner's details (as in a
W-8BEN) and statement
that beneficial owner is
not a U.S. person.
No allocation information.
Clearstream Banking
Customer Tax Guide - United States of America
March 2013
A - 13
United States of America - Appendices
Appendix 4. IRS Form W-8BEN (Certification of Foreign Status of
Beneficial Owner for U.S. Tax Withholding)
Form
W-8BEN
Certificate of Foreign Status of Beneficial Owner
for United States Tax Withholding
(Rev. February 2006)
Department of the Treasury
Internal Revenue Service
䊳
Do not use this form for:
● A U.S. citizen or other U.S. person, including a resident alien individual
● A person claiming that income is effectively connected with the conduct
of a trade or business in the United States
● A foreign partnership, a foreign simple trust, or a foreign grantor trust (see instructions for exceptions)
● A foreign government, international organization, foreign central bank of issue, foreign tax-exempt organization,
foreign private foundation, or government of a U.S. possession that received effectively connected income or that is
claiming the applicability of section(s) 115(2), 501(c), 892, 895, or 1443(b) (see instructions)
Note: These entities should use Form W-8BEN if they are claiming treaty benefits or are providing the form only to
claim they are a foreign person exempt from backup withholding.
● A person acting as an intermediary
Note: See instructions for additional exceptions.
Identification of Beneficial Owner (See instructions.)
Part I
1
Name of individual or organization that is the beneficial owner
3
Type of beneficial owner:
Grantor trust
Central bank of issue
4
Individual
Corporation
Complex trust
Estate
Tax-exempt organization
Private foundation
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Mailing address (if different from above)
City or town, state or province. Include postal code where appropriate.
6
U.S. taxpayer identification number, if required (see instructions)
SSN or ITIN
8
Reference number(s) (see instructions)
10
W-8ECI or W-8EXP
W-8IMY
Country of incorporation or organization
Disregarded entity
Partnership
Government
International organization
Simple trust
Country (do not abbreviate)
Country (do not abbreviate)
7
Foreign tax identifying number, if any (optional)
EIN
Claim of Tax Treaty Benefits (if applicable)
Part II
9
W-8ECI
W-8ECI or W-8IMY
Permanent residence address (street, apt. or suite no., or rural route). Do not use a P.O. box or in-care-of address.
City or town, state or province. Include postal code where appropriate.
5
Instead, use Form:
W-9
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2
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OMB No. 1545-1621
Section references are to the Internal Revenue Code. 䊳 See separate instructions.
䊳 Give this form to the withholding agent or payer. Do not send to the IRS.
I certify that (check all that apply):
a
The beneficial owner is a resident of
b
If required, the U.S. taxpayer identification number is stated on line 6 (see instructions).
within the meaning of the income tax treaty between the United States and that country.
c
The beneficial owner is not an individual, derives the item (or items) of income for which the treaty benefits are claimed, and, if
applicable, meets the requirements of the treaty provision dealing with limitation on benefits (see instructions).
d
The beneficial owner is not an individual, is claiming treaty benefits for dividends received from a foreign corporation or interest from a
U.S. trade or business of a foreign corporation, and meets qualified resident status (see instructions).
e
The beneficial owner is related to the person obligated to pay the income within the meaning of section 267(b) or 707(b), and will file
Form 8833 if the amount subject to withholding received during a calendar year exceeds, in the aggregate, $500,000.
Special rates and conditions (if applicable—see instructions): The beneficial owner is claiming the provisions of Article
% rate of withholding on (specify type of income):
treaty identified on line 9a above to claim a
Explain the reasons the beneficial owner meets the terms of the treaty article:
Notional Principal Contracts
Part III
11
of the
.
I have provided or will provide a statement that identifies those notional principal contracts from which the income is not effectively
connected with the conduct of a trade or business in the United States. I agree to update this statement as required.
Part IV
Certification
Under penalties of perjury, I declare that I have examined the information on this form and to the best of my knowledge and belief it is true, correct, and complete. I
further certify under penalties of perjury that:
1 I am the beneficial owner (or am authorized to sign for the beneficial owner) of all the income to which this form relates,
2 The beneficial owner is not a U.S. person,
3 The income to which this form relates is (a) not effectively connected with the conduct of a trade or business in the United States, (b) effectively connected but is
not subject to tax under an income tax treaty, or (c) the partner’s share of a partnership’s effectively connected income, and
4 For broker transactions or barter exchanges, the beneficial owner is an exempt foreign person as defined in the instructions.
Furthermore, I authorize this form to be provided to any withholding agent that has control, receipt, or custody of the income of which I am the beneficial owner or
any withholding agent that can disburse or make payments of the income of which I am the beneficial owner.
Sign Here
䊳
Signature of beneficial owner (or individual authorized to sign for beneficial owner)
For Paperwork Reduction Act Notice, see separate instructions.
Date (MM-DD-YYYY)
Cat. No. 25047Z
Capacity in which acting
Form
W-8BEN
(Rev. 2-2006)
Printed on Recycled Paper
March 2013
A - 14
Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 5. IRS Form W-8EXP (Certificate of Foreign Government or
other Foreign Organisation for U.S. Tax Withholding)
Form
Certificate of Foreign Government or Other Foreign
Organization for United States Tax Withholding
W-8EXP
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(Rev. February 2006)
Department of the Treasury
Internal Revenue Service
(For use by foreign governments, international organizations, foreign central banks of
issue, foreign tax-exempt organizations, foreign private foundations, and governments of
U.S. possessions.)
䊳 Section references are to the Internal Revenue Code.
䊳 See separate instructions.
䊳 Give this form to the withholding agent or payer. Do not send to the IRS.
Do not use this form for:
OMB No. 1545-1621
Instead, use Form:
● Any foreign government or other foreign organization that is not claiming the applicability of section(s) 115(2), 501(c),
892, 895, or 1443(b)
W-8BEN or W-8ECI
● A beneficial owner solely claiming foreign status or treaty benefits
W-8BEN
● A foreign partnership or a foreign trust
● A person claimimg that income is effectively connected with the conduct of a trade or business in the United States
● A person acting as an intermediary
Part I
W-8BEN or W-8IMY
W-8ECI
W-8IMY
Identification of Beneficial Owner (See instructions before completing this part.)
2 Country of incorporation or organization
1 Name of organization
3 Type of
entity
Foreign central bank of issue
(not wholly owned by the
foreign sovereign)
Foreign government
International organization
Government of a U.S. possession
Foreign tax-exempt organization
Foreign private foundation
4 Permanent address (street, apt. or suite no., or rural route). Do not use a P.O. box.
Country (do not abbreviate)
City or town, state or province. Include postal code where appropriate.
5 Mailing address (if different from above)
City or town, state or province. Include postal or ZIP code where appropriate.
6 U.S. taxpayer identification number, if required (see instructions)
Country (do not abbreviate)
7 Foreign tax identifying number, if any (optional)
8 Reference number(s) (see instructions)
Part II
9
Qualification Statement
For a foreign government:
I certify that the entity identified in Part I is a foreign government within the meaning of section 892 and the payments
are within the scope of the exemption granted by section 892.
Check box 9b or box 9c, whichever applies:
The entity identified in Part I is an integral part of the government of
b
.
.
The entity identified in Part I is a controlled entity of the government of
c
a
10
11
oF
For an international organization:
I certify that:
● The entity identified in Part I is an international organization within the meaning of section 7701(a)(18) and
● The payments are within the scope of the exemption granted by section 892.
For a foreign central bank of issue (not wholly owned by the foreign sovereign):
I certify that:
● The entity identified in Part I is a foreign central bank of issue,
● The entity identified in Part I does not hold obligations or bank deposits to which this form relates for use in
connection with the conduct of a commercial banking function or other commercial activity, and
● The payments are within the scope of the exemption granted by section 895.
For Paperwork Reduction Act Notice, see separate instructions.
Clearstream Banking
Customer Tax Guide - United States of America
(Part II and required certification continued on page 2)
Cat. No. 25401F
Form
W-8EXP
(Rev. 2-2006)
March 2013
A - 15
United States of America - Appendices
Appendix 5 (cont).
IRS Form W-8EXP (Certificate of Foreign Government or other
Foreign Organisation for U.S. Tax Withholding)
Form W-8EXP (Rev. 2-2006)
Part II
12
Page
2
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Qualification Statement (continued)
For a foreign tax-exempt organization, including foreign private foundations:
If any of the income to which this certification relates constitutes income includible under section 512 in computing the
entity’s unrelated business taxable income, attach a statement identifying the amounts.
Check either box 12a or box 12b:
a
I certify that the entity identified in Part I has been issued a determination letter by the IRS dated
that is currently in effect and that concludes that it is an exempt organization described in section 501(c).
b
I have attached to this form an opinion from U.S. counsel concluding that the entity identified in Part I is described in
section 501(c).
For section 501(c)(3) organizations only, check either box 12c or box 12d:
c
If the determination letter or opinion of counsel concludes that the entity identified in Part I is described in section
501(c)(3), I certify that the organization is not a private foundation described in section 509. I have attached an affidavit
of the organization setting forth sufficient facts for the IRS to determine that the organization is not a private foundation
because it meets one of the exceptions described in section 509(a)(1), (2), (3), or (4).
d
13
If the determination letter or opinion of counsel concludes that the entity identified in Part I is described in section
501(c)(3), I certify that the organization is a private foundation described in section 509.
For a government of a U.S. possession:
I certify that the entity identified in Part I is a government of a possession of the United States, or is a political
subdivision thereof, and is claiming the exemption granted by section 115(2).
Part III
Certification
Under penalties of perjury, I declare that I have examined the information on this form and to the best of my knowledge and
belief it is true, correct, and complete. I further certify under penalties of perjury that:
● The organization for which I am signing is the beneficial owner of the income to which this form relates,
● The beneficial owner is not a U.S. person,
● For a beneficial owner that is a controlled entity of a foreign sovereign (other than a central bank of issue wholly owned by
a foreign sovereign), the beneficial owner is not engaged in commercial activities within or outside the United States, and
● For a beneficial owner that is a central bank of issue wholly owned by a foreign sovereign, the beneficial owner is not
engaged in commercial activities within the United States.
Furthermore, I authorize this form to be provided to any withholding agent that has control, receipt, or custody of the income
of which I am the beneficial owner or any withholding agent that can disburse or make payments of the income of which I
am the beneficial owner.
Sign
Here
Signature of authorized official
oF
March 2013
A - 16
Date (MM-DD-YYYY)
Capacity in which acting
Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 6. IRS Form W-8ECI (Certification of Foreign Person's Claim for
Exemption from Withholding on Income Effectively Connected
with the conduct of a Trade or Business in the U.S.)
Form
Certificate of Foreign Person’s Claim That Income Is
Effectively Connected With the Conduct of a Trade or
Business in the United States
W-8ECI
(Rev. February 2006)
Department of the Treasury
Internal Revenue Service
䊳
lon y
OMB No. 1545-1621
䊳 See separate instructions.
Section references are to the Internal Revenue Code.
䊳 Give this form to the withholding agent or payer. Do not send to the IRS.
Note: Persons submitting this form must file an annual U.S. income tax return to report income claimed to be effectively
connected with a U.S. trade or business (see instructions).
Do not use this form for:
Instead, use Form:
● A beneficial owner solely claiming foreign status or treaty benefits
s
es
● A foreign government, international organization, foreign central bank of issue, foreign tax-exempt organization, foreign private
foundation, or government of a U.S. possession claiming the applicability of section(s) 115(2), 501(c), 892, 895, or 1443(b)
W-8BEN
W-8EXP
Note: These entities should use Form W-8ECI if they received effectively connected income (e.g., income from commercial activities).
● A foreign partnership or a foreign trust (unless claiming an exemption from U.S. withholding on income effectively
W-8BEN or W-8IMY
connected with the conduct of a trade or business in the United States)
W-8IMY
● A person acting as an intermediary
o
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Note: See instructions for additional exceptions.
Part I
Identification of Beneficial Owner (See instructions.)
1
Name of individual or organization that is the beneficial owner
3
Type of entity (check the appropriate box):
Partnership
Government
Private foundation
4
2
Individual
Country of incorporation or organization
Corporation
Complex trust
Central bank of issue
Simple trust
Grantor trust
International organization
Permanent residence address (street, apt. or suite no., or rural route). Do not use a P.O. box.
City or town, state or province. Include postal code where appropriate.
5
Disregarded entity
Estate
Tax-exempt organization
Country (do not abbreviate)
Business address in the United States (street, apt. or suite no., or rural route). Do not use a P.O. box.
City or town, state, and ZIP code
6
U.S. taxpayer identification number (required—see instructions)
SSN or ITIN
7
Foreign tax identifying number, if any (optional)
EIN
8
Reference number(s) (see instructions)
9
Specify each item of income that is, or is expected to be, received from the payer that is effectively connected with the conduct of a trade
or business in the United States (attach statement if necessary)
i
r
Fo
Part II
Sign
Here
Certification
Under penalties of perjury, I declare that I have examined the information on this form and to the best of my knowledge and belief it is true, correct,
and complete. I further certify under penalties of perjury that:
● I am the beneficial owner (or I am authorized to sign for the beneficial owner) of all the income to which this form relates,
● The amounts for which this certification is provided are effectively connected with the conduct of a trade or business in the United States
and are includible in my gross income (or the beneficial owner’s gross income) for the taxable year, and
● The beneficial owner is not a U.S. person.
Furthermore, I authorize this form to be provided to any withholding agent that has control, receipt, or custody of the income of which I am the
beneficial owner or any withholding agent that can disburse or make payments of the income of which I am the beneficial owner.
Signature of beneficial owner (or individual authorized to sign for the beneficial owner)
For Paperwork Reduction Act Notice, see separate instructions.
Clearstream Banking
Customer Tax Guide - United States of America
Date (MM-DD-YYYY)
Cat. No. 25045D
Capacity in which acting
Form
W-8ECI
(Rev. 2-2006)
March 2013
A - 17
United States of America - Appendices
Appendix 7. IRS Form W-8IMY (Certificate of Foreign Intermediary,
Foreign Flow-Through Entity, or Certain U.S. Branches for
U.S. Tax Withholding)
Form
W-8IMY
Certificate of Foreign Intermediary,
Foreign Flow-Through Entity, or Certain U.S.
Branches for United States Tax Withholding
lon y
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(Rev. February 2006)
Department of the Treasury
Internal Revenue Service
䊳
OMB No. 1545-1621
䊳 See separate instructions.
Section references are to the Internal Revenue Code.
䊳 Give this form to the withholding agent or payer. Do not send to the IRS.
Do not use this form for:
Instead, use Form:
● A beneficial owner solely claiming foreign status or treaty benefits
W-8BEN
● A hybrid entity claiming treaty benefits on its own behalf
W-8BEN
● A person claiming that income is effectively connected with the conduct of a trade or business in the United States
W-8ECI
● A disregarded entity. Instead, the single foreign owner should use
W-8BEN or W-8ECI
● A foreign government, international organization, foreign central bank of issue, foreign tax-exempt organization,
foreign private foundation, or government of a U.S. possession claiming the applicability of section(s) 115(2), 501(c), 892, 895, or 1443(b)
Part I
Identification of Entity
1
Name of individual or organization that is acting as intermediary
3
Type of entity—check the appropriate box:
2
Country of incorporation or organization
Withholding foreign trust. Complete Part V.
Nonwithholding foreign partnership. Complete Part VI.
Qualified intermediary. Complete Part II.
4
Nonqualified intermediary. Complete Part III.
Nonwithholding foreign simple trust. Complete Part VI.
U.S. branch. Complete Part IV.
Withholding foreign partnership. Complete Part V.
Nonwithholding foreign grantor trust. Complete Part VI.
Permanent residence address (street, apt. or suite no., or rural route). Do not use P.O. box.
City or town, state or province. Include postal code where appropriate.
5
Country (do not abbreviate)
Mailing address (if different from above)
City or town, state or province. Include postal code where appropriate.
6
U.S. taxpayer identification number (if required, see instructions) 䊳
SSN or ITIN
8
W-8EXP
EIN
Country (do not abbreviate)
7
Foreign tax identifying number, if any (optional)
QI-EIN
Reference number(s) (see instructions)
Part II
9a
Qualified Intermediary
(All qualified intermediaries check here) I certify that the entity identified in Part I:
● Is a qualified intermediary and is not acting for its own account with respect to the account(s) identified
on line 8 or in a withholding statement associated with this form and
● Has provided or will provide a withholding statement, as required.
b
c
Fo
Part III
10a
b
(If applicable) I certify that the entity identified in Part I has assumed primary withholding responsibility
under Chapter 3 of the Code with respect to the account(s) identified on this line 9b or in a withholding
statement associated with this form 䊳
(If applicable) I certify that the entity identified in Part I has assumed primary Form 1099 reporting and
backup withholding responsibility as authorized in its withholding agreement with the IRS with respect to
the account(s) identified on this line 9c or in a withholding statement associated with this form 䊳
Nonqualified Intermediary
(All nonqualified intermediaries check here) I certify that the entity identified in Part I is not a qualified
intermediary and is not acting for its own account.
(If applicable) I certify that the entity identified in Part I is using this form to transmit withholding certificates
and/or other documentary evidence and has provided or will provide a withholding statement, as required.
For Paperwork Reduction Act Notice, see separate instructions.
March 2013
A - 18
Cat. No. 25402Q
Form W-8IMY (Rev. 2-2006)
Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 7 (cont).
IRS Form W-8IMY (Certificate of Foreign Intermediary, Foreign
Flow-Through Entity, or Certain U.S. Branches for U.S. Tax
Withholding)
Page 2
Part IV Certain United States Branches
Note: You may use this Part if the entity identified in Part I is a U.S. branch of a foreign bank or insurance company
and is subject to certain regulatory requirements (see instructions).
I certify that the entity identified in Part I is a U.S. branch and that the payments are not effectively
11
connected with the conduct of a trade or business in the United States.
Check box 12 or box 13, whichever applies:
12
I certify that the entity identified in Part I is using this form as evidence of its agreement with the
withholding agent to be treated as a U.S. person with respect to any payments associated with this
certificate.
I certify that the entity identified in Part I:
13
● Is using this form to transmit withholding certificates or other documentary evidence for the persons for
whom the branch receives a payment and
● Has provided or will provide a withholding statement, as required.
Form W-8IMY (Rev. 2-2006)
Part V
14
Withholding Foreign Partnership or Withholding Foreign Trust
I certify that the entity identified in Part I:
● Is a withholding foreign partnership or a withhholding foreign trust and
● Has provided or will provide a withholding statement, as required.
Nonwithholding Foreign Partnership, Simple Trust, or Grantor Trust
Part VI
15
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I certify that the entity identified in Part I:
● Is a nonwithholding foreign partnership, a nonwithholding foreign simple trust, or a nonwithholding foreign
grantor trust and that the payments to which this certificate relates are not effectively connected, or are not
treated as effectively connected, with the conduct of a trade or business in the United States and
● Is using this form to transmit withholding certificates and/or other documentary evidence and has
provided or will provide a withholding statement, as required.
n
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Part VII Certification
Under penalties of perjury, I declare that I have examined the information on this form and to the best of my knowledge and belief it is true, correct, and complete.
Furthermore, I authorize this form to be provided to any withholding agent that has control, receipt, or custody of the income for which I am providing this form or
any withholding agent that can disburse or make payments of the income for which I am providing this form.
Sign Here
䊳
Signature of authorized official
Clearstream Banking
Customer Tax Guide - United States of America
Date (MM-DD-YYYY)
Form W-8IMY (Rev. 2-2006)
March 2013
A - 19
United States of America - Appendices
Appendix 8. IRS Form W-9 (Request for Taxpayer Identification Number
and Certification)
W-9
Request for Taxpayer
Identification Number and Certification
Form
(Rev. October 2007)
Department of the Treasury
Internal Revenue Service
Give form to the
requester. Do not
send to the IRS.
Print or type
See Specific Instructions on page 2.
Name (as shown on your income tax return)
Business name, if different from above
s
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up
Check appropriate box:
Individual/Sole proprietor
Corporation
Partnership
Limited liability company. Enter the tax classification (D=disregarded entity, C=corporation, P=partnership)
Other (see instructions)
Address (number, street, and apt. or suite no.)
Exempt
payee
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Requester’s name and address (optional)
City, state, and ZIP code
List account number(s) here (optional)
Part I
Taxpayer Identification Number (TIN)
Enter your TIN in the appropriate box. The TIN provided must match the name given on Line 1 to avoid
backup withholding. For individuals, this is your social security number (SSN). However, for a resident
alien, sole proprietor, or disregarded entity, see the Part I instructions on page 3. For other entities, it is
your employer identification number (EIN). If you do not have a number, see How to get a TIN on page 3.
Social security number
Note. If the account is in more than one name, see the chart on page 4 for guidelines on whose
number to enter.
Employer identification number
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Part II
Certification
Under penalties of perjury, I certify that:
or
1. The number shown on this form is my correct taxpayer identification number (or I am waiting for a number to be issued to me), and
2. I am not subject to backup withholding because: (a) I am exempt from backup withholding, or (b) I have not been notified by the Internal
Revenue Service (IRS) that I am subject to backup withholding as a result of a failure to report all interest or dividends, or (c) the IRS has
notified me that I am no longer subject to backup withholding, and
3. I am a U.S. citizen or other U.S. person (defined below).
Certification instructions. You must cross out item 2 above if you have been notified by the IRS that you are currently subject to backup
withholding because you have failed to report all interest and dividends on your tax return. For real estate transactions, item 2 does not apply.
For mortgage interest paid, acquisition or abandonment of secured property, cancellation of debt, contributions to an individual retirement
arrangement (IRA), and generally, payments other than interest and dividends, you are not required to sign the Certification, but you must
provide your correct TIN. See the instructions on page 4.
Sign
Here
Signature of
U.S. person General Instructions
Section references are to the Internal Revenue Code unless
otherwise noted.
Purpose of Form
A person who is required to file an information return with the
IRS must obtain your correct taxpayer identification number (TIN)
to report, for example, income paid to you, real estate
transactions, mortgage interest you paid, acquisition or
abandonment of secured property, cancellation of debt, or
contributions you made to an IRA.
Use Form W-9 only if you are a U.S. person (including a
resident alien), to provide your correct TIN to the person
requesting it (the requester) and, when applicable, to:
1. Certify that the TIN you are giving is correct (or you are
waiting for a number to be issued),
2. Certify that you are not subject to backup withholding, or
3. Claim exemption from backup withholding if you are a U.S.
exempt payee. If applicable, you are also certifying that as a
U.S. person, your allocable share of any partnership income from
a U.S. trade or business is not subject to the withholding tax on
foreign partners’ share of effectively connected income.
Note. If a requester gives you a form other than Form W-9 to
request your TIN, you must use the requester’s form if it is
substantially similar to this Form W-9.
● The U.S. owner of a disregarded entity and not the entity,
Cat. No. 10231X
March 2013
A - 20
Date Definition of a U.S. person. For federal tax purposes, you are
considered a U.S. person if you are:
● An individual who is a U.S. citizen or U.S. resident alien,
● A partnership, corporation, company, or association created or
organized in the United States or under the laws of the United
States,
● An estate (other than a foreign estate), or
● A domestic trust (as defined in Regulations section
301.7701-7).
Special rules for partnerships. Partnerships that conduct a
trade or business in the United States are generally required to
pay a withholding tax on any foreign partners’ share of income
from such business. Further, in certain cases where a Form W-9
has not been received, a partnership is required to presume that
a partner is a foreign person, and pay the withholding tax.
Therefore, if you are a U.S. person that is a partner in a
partnership conducting a trade or business in the United States,
provide Form W-9 to the partnership to establish your U.S.
status and avoid withholding on your share of partnership
income.
The person who gives Form W-9 to the partnership for
purposes of establishing its U.S. status and avoiding withholding
on its allocable share of net income from the partnership
conducting a trade or business in the United States is in the
following cases:
Form
W-9
(Rev. 10-2007)
Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 8 (cont).
IRS Form W-9 (Request for Taxpayer Identification Number and
Certification)
Form W-9 (Rev. 10-2007)
Page
2
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● The U.S. grantor or other owner of a grantor trust and not the
trust, and
● The U.S. trust (other than a grantor trust) and not the
beneficiaries of the trust.
4. The IRS tells you that you are subject to backup
withholding because you did not report all your interest and
dividends on your tax return (for reportable interest and
dividends only), or
Foreign person. If you are a foreign person, do not use Form
W-9. Instead, use the appropriate Form W-8 (see Publication
515, Withholding of Tax on Nonresident Aliens and Foreign
Entities).
5. You do not certify to the requester that you are not subject
to backup withholding under 4 above (for reportable interest and
dividend accounts opened after 1983 only).
Certain payees and payments are exempt from backup
withholding. See the instructions below and the separate
Instructions for the Requester of Form W-9.
Also see Special rules for partnerships on page 1.
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Nonresident alien who becomes a resident alien. Generally,
only a nonresident alien individual may use the terms of a tax
treaty to reduce or eliminate U.S. tax on certain types of income.
However, most tax treaties contain a provision known as a
“saving clause.” Exceptions specified in the saving clause may
permit an exemption from tax to continue for certain types of
income even after the payee has otherwise become a U.S.
resident alien for tax purposes.
If you are a U.S. resident alien who is relying on an exception
contained in the saving clause of a tax treaty to claim an
exemption from U.S. tax on certain types of income, you must
attach a statement to Form W-9 that specifies the following five
items:
1. The treaty country. Generally, this must be the same treaty
under which you claimed exemption from tax as a nonresident
alien.
2. The treaty article addressing the income.
3. The article number (or location) in the tax treaty that
contains the saving clause and its exceptions.
Civil penalty for false information with respect to
withholding. If you make a false statement with no reasonable
basis that results in no backup withholding, you are subject to a
$500 penalty.
Criminal penalty for falsifying information. Willfully falsifying
certifications or affirmations may subject you to criminal
penalties including fines and/or imprisonment.
Misuse of TINs. If the requester discloses or uses TINs in
violation of federal law, the requester may be subject to civil and
criminal penalties.
4. The type and amount of income that qualifies for the
exemption from tax.
Specific Instructions
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5. Sufficient facts to justify the exemption from tax under the
terms of the treaty article.
Example. Article 20 of the U.S.-China income tax treaty allows
an exemption from tax for scholarship income received by a
Chinese student temporarily present in the United States. Under
U.S. law, this student will become a resident alien for tax
purposes if his or her stay in the United States exceeds 5
calendar years. However, paragraph 2 of the first Protocol to the
U.S.-China treaty (dated April 30, 1984) allows the provisions of
Article 20 to continue to apply even after the Chinese student
becomes a resident alien of the United States. A Chinese
student who qualifies for this exception (under paragraph 2 of
the first protocol) and is relying on this exception to claim an
exemption from tax on his or her scholarship or fellowship
income would attach to Form W-9 a statement that includes the
information described above to support that exemption.
If you are a nonresident alien or a foreign entity not subject to
backup withholding, give the requester the appropriate
completed Form W-8.
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Penalties
What is backup withholding? Persons making certain payments
to you must under certain conditions withhold and pay to the
IRS 28% of such payments. This is called “backup withholding.”
Payments that may be subject to backup withholding include
interest, tax-exempt interest, dividends, broker and barter
exchange transactions, rents, royalties, nonemployee pay, and
certain payments from fishing boat operators. Real estate
transactions are not subject to backup withholding.
You will not be subject to backup withholding on payments
you receive if you give the requester your correct TIN, make the
proper certifications, and report all your taxable interest and
dividends on your tax return.
Payments you receive will be subject to backup
withholding if:
1. You do not furnish your TIN to the requester,
2. You do not certify your TIN when required (see the Part II
instructions on page 3 for details),
3. The IRS tells the requester that you furnished an incorrect
TIN,
Clearstream Banking
Customer Tax Guide - United States of America
Failure to furnish TIN. If you fail to furnish your correct TIN to a
requester, you are subject to a penalty of $50 for each such
failure unless your failure is due to reasonable cause and not to
willful neglect.
Name
If you are an individual, you must generally enter the name
shown on your income tax return. However, if you have changed
your last name, for instance, due to marriage without informing
the Social Security Administration of the name change, enter
your first name, the last name shown on your social security
card, and your new last name.
If the account is in joint names, list first, and then circle, the
name of the person or entity whose number you entered in Part I
of the form.
Sole proprietor. Enter your individual name as shown on your
income tax return on the “Name” line. You may enter your
business, trade, or “doing business as (DBA)” name on the
“Business name” line.
Limited liability company (LLC). Check the “Limited liability
company” box only and enter the appropriate code for the tax
classification (“D” for disregarded entity, “C” for corporation, “P”
for partnership) in the space provided.
For a single-member LLC (including a foreign LLC with a
domestic owner) that is disregarded as an entity separate from
its owner under Regulations section 301.7701-3, enter the
owner’s name on the “Name” line. Enter the LLC’s name on the
“Business name” line.
For an LLC classified as a partnership or a corporation, enter
the LLC’s name on the “Name” line and any business, trade, or
DBA name on the “Business name” line.
Other entities. Enter your business name as shown on required
federal tax documents on the “Name” line. This name should
match the name shown on the charter or other legal document
creating the entity. You may enter any business, trade, or DBA
name on the “Business name” line.
Note. You are requested to check the appropriate box for your
status (individual/sole proprietor, corporation, etc.).
Exempt Payee
If you are exempt from backup withholding, enter your name as
described above and check the appropriate box for your status,
then check the “Exempt payee” box in the line following the
business name, sign and date the form.
March 2013
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United States of America - Appendices
Appendix 8 (cont).
IRS Form W-9 (Request for Taxpayer Identification Number and
Certification)
Form W-9 (Rev. 10-2007)
Page
1. An organization exempt from tax under section 501(a), any
IRA, or a custodial account under section 403(b)(7) if the account
satisfies the requirements of section 401(f)(2),
2. The United States or any of its agencies or
instrumentalities,
3. A state, the District of Columbia, a possession of the United
States, or any of their political subdivisions or instrumentalities,
4. A foreign government or any of its political subdivisions,
agencies, or instrumentalities, or
5. An international organization or any of its agencies or
instrumentalities.
Other payees that may be exempt from backup withholding
include:
6. A corporation,
7. A foreign central bank of issue,
8. A dealer in securities or commodities required to register in
the United States, the District of Columbia, or a possession of
the United States,
9. A futures commission merchant registered with the
Commodity Futures Trading Commission,
10. A real estate investment trust,
11. An entity registered at all times during the tax year under
the Investment Company Act of 1940,
12. A common trust fund operated by a bank under section
584(a),
13. A financial institution,
14. A middleman known in the investment community as a
nominee or custodian, or
15. A trust exempt from tax under section 664 or described in
section 4947.
The chart below shows types of payments that may be
exempt from backup withholding. The chart applies to the
exempt payees listed above, 1 through 15.
IF the payment is for . . .
oF
THEN the payment is exempt
for . . .
Interest and dividend payments
All exempt payees except
for 9
Broker transactions
Exempt payees 1 through 13.
Also, a person registered under
the Investment Advisers Act of
1940 who regularly acts as a
broker
Barter exchange transactions
and patronage dividends
Exempt payees 1 through 5
Payments over $600 required
to be reported and direct
1
sales over $5,000
Generally, exempt
payees
2
1 through 7
1
2
See Form 1099-MISC, Miscellaneous Income, and its instructions.
However, the following payments made to a corporation (including gross
proceeds paid to an attorney under section 6045(f), even if the attorney is a
corporation) and reportable on Form 1099-MISC are not exempt from
backup withholding: medical and health care payments, attorneys’ fees, and
payments for services paid by a federal executive agency.
March 2013
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Generally, individuals (including sole proprietors) are not exempt
from backup withholding. Corporations are exempt from backup
withholding for certain payments, such as interest and dividends.
Note. If you are exempt from backup withholding, you should
still complete this form to avoid possible erroneous backup
withholding.
The following payees are exempt from backup withholding:
Part I. Taxpayer Identification
Number (TIN)
Enter your TIN in the appropriate box. If you are a resident
alien and you do not have and are not eligible to get an SSN,
your TIN is your IRS individual taxpayer identification number
(ITIN). Enter it in the social security number box. If you do not
have an ITIN, see How to get a TIN below.
If you are a sole proprietor and you have an EIN, you may
enter either your SSN or EIN. However, the IRS prefers that you
use your SSN.
If you are a single-member LLC that is disregarded as an
entity separate from its owner (see Limited liability company
(LLC) on page 2), enter the owner’s SSN (or EIN, if the owner
has one). Do not enter the disregarded entity’s EIN. If the LLC is
classified as a corporation or partnership, enter the entity’s EIN.
Note. See the chart on page 4 for further clarification of name
and TIN combinations.
How to get a TIN. If you do not have a TIN, apply for one
immediately. To apply for an SSN, get Form SS-5, Application
for a Social Security Card, from your local Social Security
Administration office or get this form online at www.ssa.gov. You
may also get this form by calling 1-800-772-1213. Use Form
W-7, Application for IRS Individual Taxpayer Identification
Number, to apply for an ITIN, or Form SS-4, Application for
Employer Identification Number, to apply for an EIN. You can
apply for an EIN online by accessing the IRS website at
www.irs.gov/businesses and clicking on Employer Identification
Number (EIN) under Starting a Business. You can get Forms W-7
and SS-4 from the IRS by visiting www.irs.gov or by calling
1-800-TAX-FORM (1-800-829-3676).
If you are asked to complete Form W-9 but do not have a TIN,
write “Applied For” in the space for the TIN, sign and date the
form, and give it to the requester. For interest and dividend
payments, and certain payments made with respect to readily
tradable instruments, generally you will have 60 days to get a
TIN and give it to the requester before you are subject to backup
withholding on payments. The 60-day rule does not apply to
other types of payments. You will be subject to backup
withholding on all such payments until you provide your TIN to
the requester.
Note. Entering “Applied For” means that you have already
applied for a TIN or that you intend to apply for one soon.
Caution: A disregarded domestic entity that has a foreign owner
must use the appropriate Form W-8.
Part II. Certification
To establish to the withholding agent that you are a U.S. person,
or resident alien, sign Form W-9. You may be requested to sign
by the withholding agent even if items 1, 4, and 5 below indicate
otherwise.
For a joint account, only the person whose TIN is shown in
Part I should sign (when required). Exempt payees, see Exempt
Payee on page 2.
Signature requirements. Complete the certification as indicated
in 1 through 5 below.
1. Interest, dividend, and barter exchange accounts
opened before 1984 and broker accounts considered active
during 1983. You must give your correct TIN, but you do not
have to sign the certification.
2. Interest, dividend, broker, and barter exchange
accounts opened after 1983 and broker accounts considered
inactive during 1983. You must sign the certification or backup
withholding will apply. If you are subject to backup withholding
and you are merely providing your correct TIN to the requester,
you must cross out item 2 in the certification before signing the
form.
Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 8 (cont).
IRS Form W-9 (Request for Taxpayer Identification Number and
Certification)
Form W-9 (Rev. 10-2007)
Page
3. Real estate transactions. You must sign the certification.
You may cross out item 2 of the certification.
4. Other payments. You must give your correct TIN, but you
do not have to sign the certification unless you have been
notified that you have previously given an incorrect TIN. “Other
payments” include payments made in the course of the
requester’s trade or business for rents, royalties, goods (other
than bills for merchandise), medical and health care services
(including payments to corporations), payments to a
nonemployee for services, payments to certain fishing boat crew
members and fishermen, and gross proceeds paid to attorneys
(including payments to corporations).
5. Mortgage interest paid by you, acquisition or
abandonment of secured property, cancellation of debt,
qualified tuition program payments (under section 529), IRA,
Coverdell ESA, Archer MSA or HSA contributions or
distributions, and pension distributions. You must give your
correct TIN, but you do not have to sign the certification.
For this type of account:
1. Individual
2. Two or more individuals (joint
account)
3. Custodian account of a minor
(Uniform Gift to Minors Act)
4. a. The usual revocable savings
trust (grantor is also trustee)
b. So-called trust account that is
not a legal or valid trust under
state law
5. Sole proprietorship or disregarded
entity owned by an individual
Give name and SSN of:
The individual
The actual owner of the account or,
if combined funds, the first
1
individual on the account
2
The minor
The grantor-trustee
The actual owner
The owner
1
2
3
4
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Give name and EIN of:
For this type of account:
6. Disregarded entity not owned by an
individual
7. A valid trust, estate, or pension trust
8. Corporate or LLC electing
corporate status on Form 8832
9. Association, club, religious,
charitable, educational, or other
tax-exempt organization
10. Partnership or multi-member LLC
11. A broker or registered nominee
12. Account with the Department of
Agriculture in the name of a public
entity (such as a state or local
government, school district, or
prison) that receives agricultural
program payments
1
1
The owner
4
Legal entity
The corporation
The organization
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Identity theft occurs when someone uses your personal
information such as your name, social security number (SSN), or
other identifying information, without your permission, to commit
fraud or other crimes. An identity thief may use your SSN to get
a job or may file a tax return using your SSN to receive a refund.
To reduce your risk:
● Protect your SSN,
● Ensure your employer is protecting your SSN, and
● Be careful when choosing a tax preparer.
Call the IRS at 1-800-829-1040 if you think your identity has
been used inappropriately for tax purposes.
Victims of identity theft who are experiencing economic harm
or a system problem, or are seeking help in resolving tax
problems that have not been resolved through normal channels,
may be eligible for Taxpayer Advocate Service (TAS) assistance.
You can reach TAS by calling the TAS toll-free case intake line
at 1-877-777-4778 or TTY/TDD 1-800-829-4059.
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What Name and Number To Give the Requester
4
Secure Your Tax Records from Identity Theft
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Protect yourself from suspicious emails or phishing
schemes. Phishing is the creation and use of email and
websites designed to mimic legitimate business emails and
websites. The most common act is sending an email to a user
falsely claiming to be an established legitimate enterprise in an
attempt to scam the user into surrendering private information
that will be used for identity theft.
The IRS does not initiate contacts with taxpayers via emails.
Also, the IRS does not request personal detailed information
through email or ask taxpayers for the PIN numbers, passwords,
or similar secret access information for their credit card, bank, or
other financial accounts.
If you receive an unsolicited email claiming to be from the IRS,
forward this message to [email protected]. You may also report
misuse of the IRS name, logo, or other IRS personal property to
the Treasury Inspector General for Tax Administration at
1-800-366-4484. You can forward suspicious emails to the
Federal Trade Commission at: [email protected] or contact them at
www.consumer.gov/idtheft or 1-877-IDTHEFT(438-4338).
Visit the IRS website at www.irs.gov to learn more about
identity theft and how to reduce your risk.
The partnership
The broker or nominee
The public entity
List first and circle the name of the person whose number you furnish. If only one person
on a joint account has an SSN, that person’s number must be furnished.
Circle the minor’s name and furnish the minor’s SSN.
You must show your individual name and you may also enter your business or “DBA”
name on the second name line. You may use either your SSN or EIN (if you have one),
but the IRS encourages you to use your SSN.
List first and circle the name of the trust, estate, or pension trust. (Do not furnish the TIN
of the personal representative or trustee unless the legal entity itself is not designated in
the account title.) Also see Special rules for partnerships on page 1.
Note. If no name is circled when more than one name is listed,
the number will be considered to be that of the first name listed.
Privacy Act Notice
Section 6109 of the Internal Revenue Code requires you to provide your correct TIN to persons who must file information returns with the IRS to report interest,
dividends, and certain other income paid to you, mortgage interest you paid, the acquisition or abandonment of secured property, cancellation of debt, or
contributions you made to an IRA, or Archer MSA or HSA. The IRS uses the numbers for identification purposes and to help verify the accuracy of your tax return.
The IRS may also provide this information to the Department of Justice for civil and criminal litigation, and to cities, states, the District of Columbia, and U.S.
possessions to carry out their tax laws. We may also disclose this information to other countries under a tax treaty, to federal and state agencies to enforce federal
nontax criminal laws, or to federal law enforcement and intelligence agencies to combat terrorism.
You must provide your TIN whether or not you are required to file a tax return. Payers must generally withhold 28% of taxable interest, dividend, and certain other
payments to a payee who does not give a TIN to a payer. Certain penalties may also apply.
Clearstream Banking
Customer Tax Guide - United States of America
March 2013
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United States of America - Appendices
Appendix 9. Withholding Statement - Non-U.S. Beneficial Owners
With respect to account number(s) __________________________________________________ (the “Account(s)”)
with Clearstream Banking société anonyme (“Clearstream Banking SA”), we hereby certify that we are not a U.S.
person and we are the Beneficial Owner of all U.S. Securities that are, or may be, held in the Account(s) from time
to time and of all Reportable Amounts paid on such U.S. Securities and are: (tick one box only)

A Non-U.S. Beneficial Owner entitled to the ___________% reduced double taxation treaty rate with respect
to Dividends, a tax exemption with respect to Portfolio Interest and a tax exemption for short-term Original
Issue Discount (OID) and bank Certificate of Deposit (CD) interest; or

A Non-U.S. Beneficial Owner entitled to the ___________% reduced double taxation treaty rate with respect
to Dividends, a _________% reduced double taxation treaty rate with respect to long-term OID and pre-1984
bond issues, a tax exemption for Portfolio Interest and a tax exemption for short-term OID and bank CD
Interest; or

A Non-U.S. Beneficial Owner, not claiming the benefit of a U.S. income tax treaty with respect to Dividends
but entitled to a tax exemption for short-term OID and bank CD Interest.
Attached is Form W-8BEN, completed in the name of the Beneficial Owner.
OR

A Non-U.S. Beneficial Owner that is a Foreign Government, International Organisation, Foreign Central
Bank or a Foreign Tax Exempt Organisation (other than a Foreign Private Foundation) entitled to an
Exemption from Non-Resident Alien (NRA) withholding tax on all Reportable Amounts; or

A Non-U.S. Beneficial Owner that is a Foreign Private Foundation, entitled to the reduced 4% withholding
tax rate with respect to Dividends, Interest and long-term OID, and an Exemption for short-term OID and
bank CD Interest.
Attached is Form W-8EXP, completed in the name of the Beneficial Owner.
OR

A Non-U.S. Beneficial Owner for which all Reportable Amounts constitute Effectively Connected Income
with a trade or business conducted in the U.S.A. are exempt from NRA withholding.
Attached is Form W-8ECI, completed in the name of the Beneficial Owner.
March 2013
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Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 9 (cont).
Withholding Statement - Non-U.S. Beneficial Owners
Notifications
We undertake to notify Clearstream Banking SA at the latest by 10:00 Central European Time on the Business Day
prior to any relevant Payment Date of any balance of U.S. Securities that is not covered by this withholding
statement or by the attached IRS Form(s) or documentation.
We hereby undertake to notify Clearstream Banking SA promptly, and at the latest within 30 days, of any changes
to the information included in this withholding statement or the attached forms and documentation to which this
instruction refers.
We hereby undertake to provide Clearstream Banking SA, within its deadline, with any additional statements,
certifications, Forms, documentation or information that may be required under the U.S. Internal Revenue Code
(IRC) or the regulations thereunder.
Reporting
We hereby appoint Clearstream Banking SA and Clearstream Banking SA’s U.S. Tax Reporting Agent as our
attorneys-in-fact with authority to collect and forward any information or documents to the IRS to the extent
required under Section 1.1441 of the IRC as amended and the regulations thereunder.
We similarly appoint them to collect and forward any information or documents to other persons holding the
relevant U.S. Securities for the account of Clearstream Banking SA or from whom Clearstream Banking SA
receives payments on such securities.
We irrevocably authorise Clearstream Banking SA to disclose this certificate or any copy, attachments or related
information to the interested party, in the event of or threat of administrative or legal proceedings, an official inquiry
or request of the U.S. Internal Revenue Service or other relevant authority, in which or to which this withholding
statement (including any certificate, Form, document or other information referred to herein) is, or would be, relevant.
Undertakings
We agree irrevocably that, in the event that:
i) we fail to deliver any certificate, Form or document necessary under the U.S. Internal Revenue Code of 1986
as amended, the regulations issued thereunder, the Qualified Intermediary Agreement published in Revenue
Procedure 2000-12 as amended or Clearstream Banking SA Governing Documents; or
ii) this certificate or any certificate, Form or information referred to herein and delivered by us to Clearstream
Banking SA is incorrect, outdated, incomplete or invalid for any reason within our control or within our knowledge;
then we shall indemnify Clearstream Banking SA for any resulting loss, claim, liability or expense. This includes
penalties and resulting additions to tax and interest thereon (and reasonable expenses of counsel). Moreover,
Clearstream Banking SA may charge our account or otherwise reclaim from us and we will pay Clearstream
Banking SA on demand the amount of such charge or loss and any other expenses incurred by Clearstream
Banking SA in pursuing their claim.
We understand that:
i) If this certificate or any attached or connected certificate, Form or document or any information furnished by
us is found to be false, we may be liable for damages and could also be subject to such other sanctions as
may be determined by the Secretary of the U.S. Department of the Treasury or Internal Revenue Service; and
ii) The U.S. Department of the Treasury or Internal Revenue Service may determine that any certificate or
statement given by us will not be valid to prevent the imposition of the 30% U.S. withholding tax on payments to
us of interest that would otherwise qualify for exemption from such tax as “portfolio interest” within the meaning
of sections 871(h) and 881(c) of the Code. The U.S. Department of the Treasury or IRS may further determine
that any certificate or statement given by us will be ineffectual in the preclusion of or entitlement to a reduction
of the imposition of the 30% U.S. withholding tax on payments to us of dividends within the meaning of the Code.
Clearstream Banking
Customer Tax Guide - United States of America
March 2013
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United States of America - Appendices
Appendix 9 (cont).
Withholding Statement - Non-U.S. Beneficial Owners
Definitions
For the purposes of this Withholding Statement:
• “Beneficial Owner” means, with respect to a Security, any person that under sections 871(h)(2)(B)(ii) and
881(c)(2)(B)(ii) of the Code is considered to be the beneficial owner of that Security.
• “Code” means the U.S. Internal Revenue Code of 1986 as amended. Any reference to any section of the
Code shall mean such section of any successor provisions.
• “Form” means a U.S. Internal Revenue Service form or such successor form as shall be adopted from time
to time by the U.S. Internal Revenue Service and any substantially similar substitute form as may be
permitted by the Code or the regulations thereunder.
• All terms that are used and not defined herein shall have the meanings given to them in the Internal
Revenue Code of 1986 as amended, the regulations issued thereunder, the Qualified Intermediary
Agreement published in Revenue Procedure 2000-12 as amended and Clearstream Banking SA Governing
Documents.
Certification
This statement forms an integral part of the attached withholding certificate. We hereby certify, under penalties of
perjury, that the above information is true, correct and complete and that I am/we are the (an) authorised
representative(s) of the Customer named below.
Name of Clearstream Banking Customer: __________________________________________________________
Address: _____________________________________________________________________________________
____________________________________________________________________________________________
____________________________________________________________________________________________
Customer account number: ______________________________________________________________________
.
Authorised Signature
Authorised Signature
Name
Name
Title
Title
Place
Date
March 2013
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Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 10. Withholding Statement - U.S. Persons
With respect to account number(s) ____________________________ (the “Account(s)”) with Clearstream Banking
société anonyme, (“Clearstream Banking SA”), we hereby certify that with respect to all U.S. Securities that are, or
may be, held in the Account(s) from time to time and to all Reportable Amounts paid on such U.S. Securities:
We are a U.S. Corporation or Partnership and with respect to U.S. Securities that are, or may be, held in the
Account(s) from time to time, we are not acting as a Qualified Intermediary (QI) through a branch outside the U.S.A.
Our taxpayer identification number (TIN) is: _______________________________________
We have attached hereto a Form W-9, duly completed confirming our status as a U.S. Corporation or Partnership
(or substantially similar substitute form completed under penalty of perjury). If such status changes, we undertake
promptly, but in any event within 30 days, to notify Clearstream Banking SA of such a change.
Notifications
We undertake to notify Clearstream Banking SA at the latest by 10:00 Central European Time on the Business Day
prior to any relevant Payment Date of any balance of U.S. Securities that is not covered by this withholding
statement or by the attached IRS Form(s) or documentation.
We hereby undertake to notify Clearstream Banking SA promptly, and at the latest within 30 days, of any changes
to the information included in this withholding statement or the attached forms and documentation to which this
instruction refers.
We hereby undertake to provide Clearstream Banking SA, within its deadline, with any additional statements,
certifications, Forms, documentation, allocations or information that may be required under the U.S. Internal
Revenue Code (IRC) or the regulations thereunder.
Reporting
We hereby appoint Clearstream Banking SA and Clearstream Banking SA’s U.S. Tax Reporting Agent as our
attorneys-in-fact with authority to collect and forward any information or documents to the IRS to the extent
required under Section 1.1441 of the IRC as amended and the regulations thereunder.
We similarly appoint them to collect and forward any information or documents to other persons holding the
relevant U.S. Securities for the account of Clearstream Banking SA or from whom Clearstream Banking SA
receives payments on such securities.
We irrevocably authorise Clearstream Banking SA to disclose this certificate or any copy, attachments or related
information to the interested party, in the event of or threat of administrative or legal proceedings, an official inquiry
or request of the U.S. Internal Revenue Service or other relevant authority, in which or to which this withholding
statement (including any certificate, Form, document or other information referred to herein) is, or would be, relevant.
Undertakings
We agree irrevocably that, in the event that:
i) we fail to deliver any certificate, Form or document necessary under the U.S. Internal Revenue Code of 1986
as amended, the regulations issued thereunder, the Qualified Intermediary Agreement published in Revenue
Procedure 2000-12 as amended or Clearstream Banking SA Governing Documents; or
ii) this certificate or any certificate, Form or information referred to herein and delivered by us to Clearstream
Banking SA is incorrect, outdated, incomplete or invalid for any reason within our control or within our knowledge;
then we shall indemnify Clearstream Banking SA for any resulting loss, claim, liability or expense. This includes
penalties and resulting additions to tax and interest thereon (and reasonable expenses of counsel). Moreover,
Clearstream Banking SA may charge our account or otherwise reclaim from us and we will pay Clearstream
Banking SA on demand the amount of such charge or loss and any other expenses incurred by Clearstream
Banking SA in pursuing their claim.
We understand that:
i) If this certificate or any attached or connected certificate, Form or document or any information furnished by
us is found to be false, we may be liable for damages and could also be subject to such other sanctions as
may be determined by the Secretary of the U.S. Department of the Treasury or Internal Revenue Service; and
Clearstream Banking
Customer Tax Guide - United States of America
March 2013
A - 27
United States of America - Appendices
Appendix 10 (cont). Withholding Statement - U.S. Persons
ii) The U.S. Department of the Treasury or Internal Revenue Service may determine that any certificate or
statement given by us will not be valid to prevent the imposition of the 30% U.S. withholding tax on payments to
us of interest that would otherwise qualify for exemption from such tax as “portfolio interest” within the meaning
of sections 871(h) and 881(c) of the Code. The U.S. Department of the Treasury or IRS may further determine
that any certificate or statement given by us will be ineffectual in the preclusion of or entitlement to a reduction
of the imposition of the 30% U.S. withholding tax on payments to us of dividends within the meaning of the Code.
Definitions
For the purposes of this Withholding Statement:
• “Beneficial Owner” means, with respect to a Security, any person that under sections 871(h)(2)(B)(ii) and
881(c)(2)(B)(ii) of the Code is considered to be the beneficial owner of that Security.
• “Code” means the U.S. Internal Revenue Code of 1986 as amended. Any reference to any section of the
Code shall mean such section of any successor provisions.
• “Form” means a U.S. Internal Revenue Service form or such successor form as shall be adopted from time
to time by the U.S. Internal Revenue Service and any substantially similar substitute form as may be
permitted by the Code or the regulations thereunder.
• All terms that are used and not defined herein shall have the meanings given to them in the Internal
Revenue Code of 1986 as amended, the regulations issued thereunder, the Qualified Intermediary
Agreement published in Revenue Procedure 2000-12 as amended and Clearstream Banking SA Governing
Documents.
Certification
This statement forms an integral part of the attached withholding certificate. We hereby certify, under penalties of
perjury, that the above information is true, correct and complete and that I am/we are the (an) authorised
representative(s) of the Customer named below.
Name of Clearstream Banking Customer: __________________________________________________________
Address: _____________________________________________________________________________________
____________________________________________________________________________________________
____________________________________________________________________________________________
Customer account number: ______________________________________________________________________
.
Authorised Signature
Authorised Signature
Name
Name
Title
Title
Place
Date
March 2013
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Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 11. Withholding Statement - QI-A Account
With respect to account number(s) __________________________________________________ (the “Account(s)”)
with Clearstream Banking société anonyme (hereinafter “Clearstream Banking SA”), we hereby certify that with
respect to all U.S. Securities that are, or may be, held in the Account(s) from time to time and to all Reportable
Amounts paid on such U.S. Securities, we are acting as: (tick one box only)

A Qualified Intermediary (QI) and we have assumed primary Non-Resident Alien (NRA) withholding
responsibility and 1099 reporting and backup withholding responsibility with respect to all U.S. Securities
held in the Account(s); or

A Withholding Foreign Partnership and therefore have primary NRA withholding responsibility and backup
withholding responsibility; or

A U.S. branch described in U.S. Treasury Regulations Section 1.1441-1(b)(2)(iv)(A) that is treated as a U.S.
person and therefore have primary NRA withholding responsibility and backup withholding responsibility.
Attached is Form W-8IMY, duly completed in our name confirming our intermediary status.
Notifications
We undertake to notify Clearstream Banking SA at the latest by 10:00 Central European Time two Business Days
prior to any relevant Payment Date of any balance of U.S. Securities that is not covered by this withholding
statement or by the attached IRS Form(s) or documentation.
We hereby undertake to notify Clearstream Banking SA promptly, and at the latest within 30 days, of any changes
to the information included in this withholding statement or the attached forms and documentation to which this
instruction refers.
We hereby undertake to provide Clearstream Banking SA, within its deadline, with any additional statements,
certifications, Forms, documentation or information that may be required under the U.S. Internal Revenue Code
(IRC) or the regulations thereunder.
Reporting
We hereby appoint Clearstream Banking SA and Clearstream Banking SA’s U.S. Tax Reporting Agent as our
attorneys-in-fact with authority to collect and forward any information or documents to the IRS to the extent
required under Section 1.1441 of the IRC as amended and the regulations thereunder.
We similarly appoint them to collect and forward any information or documents to other persons holding the
relevant U.S. Securities for the account of Clearstream Banking SA or from whom Clearstream Banking SA
receives payments on such securities.
We irrevocably authorise Clearstream Banking SA to disclose this certificate or any copy, attachments or related
information to the interested party, in the event of or threat of administrative or legal proceedings, an official inquiry
or request of the U.S. Internal Revenue Service or other relevant authority, in which or to which this withholding
statement (including any certificate, Form, document or other information referred to herein) is, or would be,
relevant.
Clearstream Banking
Customer Tax Guide - United States of America
March 2013
A - 29
United States of America - Appendices
Appendix 11 (cont). Withholding Statement - QI-A Account
Undertakings
We agree irrevocably that, in the event that:
i) we fail to deliver any certificate, Form or document necessary under the U.S. Internal Revenue Code of 1986
as amended, the regulations issued thereunder, the Qualified Intermediary Agreement published in Revenue
Procedure 2000-12 as amended or Clearstream Banking SA Governing Documents; or
ii) this certificate or any certificate, Form or information referred to herein and delivered by us to Clearstream
Banking SA is incorrect, outdated, incomplete or invalid for any reason within our control or within our
knowledge;
then we shall indemnify Clearstream Banking SA for any resulting loss, claim, liability or expense. This includes
penalties and resulting additions to tax and interest thereon (and reasonable expenses of counsel). Moreover,
Clearstream Banking SA may charge our account or otherwise reclaim from us and we will pay Clearstream
Banking SA on demand the amount of such charge or loss and any other expenses incurred by Clearstream
Banking SA in pursuing their claim.
We understand that:
i) If this certificate or any attached or connected certificate, Form or document or any information furnished by
us is found to be false, we may be liable for damages and could also be subject to such other sanctions as
may be determined by the Secretary of the U.S. Department of the Treasury or Internal Revenue Service; and
ii) The U.S. Department of the Treasury or Internal Revenue Service may determine that any certificate or
statement given by us will not be valid to prevent the imposition of the 30% U.S. withholding tax on payments to
us of interest that would otherwise qualify for exemption from such tax as “portfolio interest” within the meaning
of sections 871(h) and 881(c) of the Code. The U.S. Department of the Treasury or IRS may further determine
that any certificate or statement given by us will be ineffectual in the preclusion of or entitlement to a reduction
of the imposition of the 30% U.S. withholding tax on payments to us of dividends within the meaning of the Code.
Definitions
For the purposes of this Withholding Statement:
• “Beneficial Owner” means, with respect to a Security, any person that under sections 871(h)(2)(B)(ii) and
881(c)(2)(B)(ii) of the Code is considered to be the beneficial owner of that Security.
• “Code” means the U.S. Internal Revenue Code of 1986 as amended. Any reference to any section of the
Code shall mean such section of any successor provisions.
• “Form” means a U.S. Internal Revenue Service form or such successor form as shall be adopted from time
to time by the U.S. Internal Revenue Service and any substantially similar substitute form as may be
permitted by the Code or the regulations thereunder.
• All terms that are used and not defined herein shall have the meanings given to them in the Internal
Revenue Code of 1986 as amended, the regulations issued thereunder, the Qualified Intermediary
Agreement published in Revenue Procedure 2000-12 as amended and Clearstream Banking SA Governing
Documents.
March 2013
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Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 11 (cont). Withholding Statement - QI-A Account
Certification
This statement forms an integral part of the attached withholding certificate. We hereby certify, under penalties of
perjury, that the above information is true, correct and complete and that I am/we are the (an) authorised
representative(s) of the Customer named below.
Name of Clearstream Banking Customer: __________________________________________________________
Address: ____________________________________________________________________________________
____________________________________________________________________________________________
____________________________________________________________________________________________
Customer account number: ______________________________________________________________________
.
Authorised Signature
Authorised Signature
Name
Name
Title
Title
Place
Date
Clearstream Banking
Customer Tax Guide - United States of America
March 2013
A - 31
United States of America - Appendices
Appendix 12. Withholding Statement - QI-B Account
With respect to account number(s) __________________________________________________ (the “Account(s)”)
with Clearstream Banking société anonyme, (hereinafter “Clearstream Banking SA”), we hereby certify that with
respect to all U.S. Securities that are, or may be, held in the Account(s) from time to time and to all Reportable
Amounts paid on such U.S. Securities, we are acting as: (tick one box only)

A Qualified Intermediary (QI) and the U.S. Securities in the Account(s) are held exclusively for the account of
non-U.S. beneficial owners or U.S. exempt recipients and we have assumed primary Non-Resident Alien
(NRA) withholding responsibility with respect to all U.S. Securitiies held in the Account(s);
Attached is Form W-8IMY, duly completed in our name confirming our intermediary status.
OR

A Qualified Intermediary and the U.S. Securities in the Account are held exclusively for the account of U.S.
non-exempt recipients and we have not assumed 1099 reporting and backup withholding responsibility
with respect to all U.S. Securitiies held in the Account(s);
AND: (tick one box only)

The U.S. Securities in the Account(s) are held exclusively for the account of a single U.S. non-exempt recipient:
• We attach hereto a Form W-9 duly completed and signed by such U.S. non-exempt recipient;
• We undertake to provide to Clearstream Banking SA upon request any further information required
for the purposes of 1099 reporting.
OR

The U.S. Securities in the Account(s) are held exclusively for the account of U.S. non-exempt recipients:
• We attach hereto a Form W-9 duly completed and signed by each such U.S. non-exempt recipient;
• We undertake to provide to Clearstream Banking SA upon request any further information required
for the purposes of 1099 reporting, including allocation information per U.S. non-exempt recipient.
OR

The U.S. Securities in the Account(s) are held exclusively for the account of U.S. non-exempt recipients whose
identity and documentation we are prohibited by law from disclosing:
• We hereby request that Clearstream Banking SA apply backup withholding tax at the current rate
on all dividend, interest and redemption payments on U.S. Securities held in the Account(s).
• We undertake to apply or to ensure that another party other than Clearstream Banking SA applies
backup withholding tax at the current rate on the proceeds of sales of U.S. Securities held in the
Account(s). We acknowledge that Clearstream Banking SA is not responsible for applying such
backup withholding tax and has not assumed such responsibility under the Designated Broker
Proceeds rules.
• We undertake not to allow U.S. Securities purchased by such U.S. non-exempt recipients after
31 December 2000 to be deposited in the Account(s).
• We undertake to disclose to Clearstream Banking SA the name and address of each U.S. nonexempt recipient, unless we are prohibited by law from doing so.
• We undertake to provide to Clearstream Banking SA upon request any further information required
for the purposes of 1099 reporting, including allocation information per U.S. non-exempt recipient
wherever disclosable.
OR

The U.S. Securities in the Account(s) are held exclusively for the account of U.S. exempt recipients.
March 2013
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Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 12 (cont). Withholding Statement - QI-B Account
Notifications
We undertake to notify Clearstream Banking SA at the latest by 10:00 Central European Time two Business Days
prior to any relevant Payment Date of any balance of U.S. Securities that is not covered by this withholding
statement or by the attached IRS Form(s) or documentation.
We hereby undertake to notify Clearstream Banking SA promptly, and at the latest within 30 days, of any changes
to the information included in this withholding statement or the attached forms and documentation to which this
instruction refers.
We hereby undertake to provide Clearstream Banking SA, within its deadline, with any additional statements,
certifications, Forms, documentation or information that may be required under the U.S. Internal Revenue Code
(IRC) or the regulations thereunder.
Reporting
We hereby appoint Clearstream Banking SA and Clearstream Banking SA’s U.S. Tax Reporting Agent as our
attorneys-in-fact with authority to collect and forward any information or documents to the IRS to the extent
required under Section 1.1441 of the IRC as amended and the regulations thereunder.
We similarly appoint them to collect and forward any information or documents to other persons holding the
relevant U.S. Securities for the account of Clearstream Banking SA or from whom Clearstream Banking SA
receives payments on such securities.
We irrevocably authorise Clearstream Banking SA to disclose this certificate or any copy, attachments or related
information to the interested party, in the event of or threat of administrative or legal proceedings, an official inquiry
or request of the U.S. Internal Revenue Service or other relevant authority, in which or to which this withholding
statement (including any certificate, Form, document or other information referred to herein) is, or would be, relevant.
Undertakings
We agree irrevocably that, in the event that:
i) we fail to deliver any certificate, Form or document necessary under the U.S. Internal Revenue Code of 1986
as amended, the regulations issued thereunder, the Qualified Intermediary Agreement published in Revenue
Procedure 2000-12 as amended or Clearstream Banking SA Governing Documents; or
ii) this certificate or any certificate, Form or information referred to herein and delivered by us to Clearstream
Banking SA is incorrect, outdated, incomplete or invalid for any reason within our control or within our
knowledge; then we shall indemnify Clearstream Banking SA for any resulting loss, claim, liability or
expense. This includes penalties and resulting additions to tax and interest thereon (and reasonable
expenses of counsel). Moreover, Clearstream Banking SA may charge our account or otherwise reclaim from
us and we will pay Clearstream Banking SA on demand the amount of such charge or loss and any other
expenses incurred by Clearstream Banking SA in pursuing their claim.
We understand that:
i) If this certificate or any attached or connected certificate, Form or document or any information furnished by
us is found to be false, we may be liable for damages and could also be subject to such other sanctions as
may be determined by the Secretary of the U.S. Department of the Treasury or Internal Revenue Service; and
ii) The U.S. Department of the Treasury or Internal Revenue Service may determine that any certificate or
statement given by us will not be valid to prevent the imposition of the 30% U.S. withholding tax on payments to
us of interest that would otherwise qualify for exemption from such tax as “portfolio interest” within the meaning
of sections 871(h) and 881(c) of the Code. The U.S. Department of the Treasury or IRS may further determine
that any certificate or statement given by us will be ineffectual in the preclusion of or entitlement to a reduction
of the imposition of the 30% U.S. withholding tax on payments to us of dividends within the meaning of the Code.
Clearstream Banking
Customer Tax Guide - United States of America
March 2013
A - 33
United States of America - Appendices
Appendix 12 (cont). Withholding Statement - QI-B Account
Definitions
For the purposes of this Withholding Statement:
• “Beneficial Owner” means, with respect to a Security, any person that under sections 871(h)(2)(B)(ii) and
881(c)(2)(B)(ii) of the Code is considered to be the beneficial owner of that Security.
• “Code” means the U.S. Internal Revenue Code of 1986 as amended. Any reference to any section of the
Code shall mean such section of any successor provisions.
• “Form” means a U.S. Internal Revenue Service form or such successor form as shall be adopted from time
to time by the U.S. Internal Revenue Service and any substantially similar substitute form as may be
permitted by the Code or the regulations thereunder.
• All terms that are used and not defined herein shall have the meanings given to them in the Internal
Revenue Code of 1986 as amended, the regulations issued thereunder, the Qualified Intermediary
Agreement published in Revenue Procedure 2000-12 as amended and Clearstream Banking SA Governing
Documents.
Certification
This statement forms an integral part of the attached withholding certificate. We hereby certify, under penalties of
perjury, that the above information is true, correct and complete and that I am/we are the (an) authorised
representative(s) of the Customer named below.
Name of Clearstream Banking Customer: __________________________________________________________
Address: _____________________________________________________________________________________
____________________________________________________________________________________________
____________________________________________________________________________________________
Customer account number: ______________________________________________________________________
.
Authorised Signature
Authorised Signature
Name
Name
Title
Title
Place
Date
March 2013
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Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 13. Withholding Statement - QI-C Account
With respect to account number(s) __________________________________________________ (the “Account(s)”)
with Clearstream Banking société anonyme (hereinafter “Clearstream Banking SA”), we hereby certify that with
respect to all U.S. Securities that are, or may be, held in the Account(s) from time to time and to all Reportable
Amounts paid on such U.S. Securities:
We have not assumed primary Non-Resident Alien (NRA) withholding responsibility and we have attached hereto
a Form W-8IMY duly completed and signed by ourselves to that effect. We are holding the U.S. Securities for:
NON-U.S. BENEFICIAL OWNER (tick one box only)
in:

An Omnibus account for Non-U.S. recipients (and U.S. exempt recipients):
We hereby undertake to notify Clearstream Banking SA of the breakdown of Reportable Amounts payable
on any U.S. Security held in the Account(s), per U.S. withholding tax rate to be applied to such payment, at
the latest by 10:00 Central European Time two Business Days prior to the Payment Date of each such
payment; we acknowledge that failing such notification by such deadline, the payment will be subject to
deduction of U.S. withholding tax at the rate of 30%.
OR

A Segregated account for a particular withholding tax rate pool:
With respect to Reportable Amounts paid on U.S. Securities held in the Account, we hereby instruct
Clearstream Banking SA to always apply U.S. withholding tax on the following types of payments (one single
rate per type of Reportable Amount) as indicated in each case (tick one box and complete as applicable):

Non-U.S. Beneficial Owners entitled to the _____% reduced double taxation treaty rate with respect
to Dividends, a tax exemption with respect to Portfolio Interest and a tax exemption for short-term
Original Issue Discount (OID) and bank Certificate of Deposit (CD) interest;

Non-U.S. Beneficial Owners entitled to the _____% reduced double taxation treaty rate with respect
to Dividends, a _______% reduced double taxation treaty rate with respect to long-term OID and pre1984 bond issues and/or a tax exemption for Portfolio Interest, short-term OID and bank CD Interest;

Non-U.S. Beneficial Owners, not claiming the benefit of a U.S. income tax treaty with respect to
Dividends but entitled to a tax exemption with respect to Portfolio Interest and a tax exemption for
short-term OID and bank CD Interest;

Non-U.S. Beneficial Owners, not claiming the benefit of a U.S. income tax treaty with respect to
Dividends, or a tax exemption with respect to Portfolio Interest, or a tax exemption for short-term OID
and bank CD Interest;

Non-U.S. Beneficial Owners entitled to full exemption from Non-Resident Alien (NRA) withholding
tax on all Reportable Amounts.
Clearstream Banking
Customer Tax Guide - United States of America
March 2013
A - 35
United States of America - Appendices
Appendix 13 (cont). Withholding Statement - QI-C Account
We are acting as a Qualified Intermediary and the U.S. Securities in the Account(s) are held exclusively for the
account of U.S. non-exempt recipients and we have not assumed 1099 reporting and backup withholding tax
responsibility with respect to all U.S. Securities held in the Account(s) for:
U.S. PERSON (tick one box only)

The U.S. Securities in the Account(s) are held exclusively for the account of a single U.S. non-exempt
recipient:
• We attach hereto a Form W-9 duly completed and signed by such U.S. non-exempt recipient;
• We undertake to provide to Clearstream Banking SA upon request any further information required
for the purposes of 1099 reporting.
OR

The U.S. Securities in the Account(s) are held exclusively for the account of U.S. non-exempt recipients:
• We attach hereto a Form W-9 duly completed and signed by each such U.S. non-exempt recipient;
• We undertake to provide to Clearstream Banking SA upon request any further information required
for the purposes of 1099 reporting, including allocation information per U.S. non-exempt recipient.
OR

The U.S. Securities in the Account(s) are held exclusively for the account of U.S. non-exempt recipients whose
identity and documentation we are prohibited by law from disclosing:
• We hereby request that Clearstream Banking SA apply backup withholding tax at the current rate
on all dividend, interest and redemption payments on U.S. Securities held in the Account(s).
• We undertake to apply or to ensure that another party other than Clearstream Banking SA applies
backup withholding tax at the current rate on the proceeds of sales of U.S. Securities held in the
Account(s). We acknowledge that Clearstream Banking SA is not responsible for applying such
backup withholding tax and has not assumed such responsibility under the Designated Broker
Proceeds rules.
• We undertake not to allow U.S. Securities purchased by such U.S. non-exempt recipients after
31 December 2000 to be deposited in the Account(s).
• We undertake to disclose to Clearstream Banking SA the name and address of each U.S. nonexempt recipient, unless we are prohibited by law from doing so.
• We undertake to provide to Clearstream Banking SA upon request any further information required
for the purposes of 1099 reporting, including allocation information per U.S. non-exempt recipient
wherever disclosable.
OR

The U.S. Securities in the Account(s) are held exclusively for the account of U.S. exempt recipients.
March 2013
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Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 13 (cont). Withholding Statement - QI-C Account
Notifications
We undertake to notify Clearstream Banking SA at the latest by 10:00 Central European Time two Business Days
prior to any relevant Payment Date of any balance of U.S. Securities that is not covered by this withholding
statement or by the attached IRS Form(s) or documentation.
We hereby undertake to notify Clearstream Banking SA promptly, and at the latest within 30 days, of any changes
to the information included in this withholding statement or the attached forms and documentation to which this
instruction refers.
We hereby undertake to provide Clearstream Banking SA, within its deadline, with any additional statements,
certifications, Forms, documentation or information that may be required under the U.S. Internal Revenue Code
(IRC) or the regulations thereunder.
Reporting
We hereby appoint Clearstream Banking SA and Clearstream Banking SA’s U.S. Tax Reporting Agent as our
attorneys-in-fact with authority to collect and forward any information or documents to the IRS to the extent
required under Section 1.1441 of the IRC as amended and the regulations thereunder.
We similarly appoint them to collect and forward any information or documents to other persons holding the
relevant U.S. Securities for the account of Clearstream Banking SA or from whom Clearstream Banking SA
receives payments on such securities.
We irrevocably authorise Clearstream Banking SA to disclose this certificate or any copy, attachments or related
information to the interested party, in the event of or threat of administrative or legal proceedings, an official inquiry
or request of the U.S. Internal Revenue Service or other relevant authority, in which or to which this withholding
statement (including any certificate, Form, document or other information referred to herein) is, or would be, relevant.
Undertakings
We agree irrevocably that, in the event that:
i) we fail to deliver any certificate, Form or document necessary under the U.S. Internal Revenue Code of 1986
as amended, the regulations issued thereunder, the Qualified Intermediary Agreement published in Revenue
Procedure 2000-12 as amended or Clearstream Banking SA Governing Documents; or
ii) this certificate or any certificate, Form or information referred to herein and delivered by us to Clearstream
Banking SA is incorrect, outdated, incomplete or invalid for any reason within our control or within our knowledge;
then we shall indemnify Clearstream Banking SA for any resulting loss, claim, liability or expense. This includes
penalties and resulting additions to tax and interest thereon (and reasonable expenses of counsel). Moreover,
Clearstream Banking SA may charge our account or otherwise reclaim from us and we will pay Clearstream
Banking SA on demand the amount of such charge or loss and any other expenses incurred by Clearstream
Banking SA in pursuing their claim.
We understand that:
i) If this certificate or any attached or connected certificate, Form or document or any information furnished by
us is found to be false, we may be liable for damages and could also be subject to such other sanctions as
may be determined by the Secretary of the U.S. Department of the Treasury or Internal Revenue Service; and
ii) The U.S. Department of the Treasury or Internal Revenue Service may determine that any certificate or
statement given by us will not be valid to prevent the imposition of the 30% U.S. withholding tax on payments to
us of interest that would otherwise qualify for exemption from such tax as “portfolio interest” within the meaning
of sections 871(h) and 881(c) of the Code. The U.S. Department of the Treasury or IRS may further determine
that any certificate or statement given by us will be ineffectual in the preclusion of or entitlement to a reduction
of the imposition of the 30% U.S. withholding tax on payments to us of dividends within the meaning of the Code.
Clearstream Banking
Customer Tax Guide - United States of America
March 2013
A - 37
United States of America - Appendices
Appendix 13 (cont). Withholding Statement - QI-C Account
Definitions
For the purposes of this Withholding Statement:
• “Beneficial Owner” means, with respect to a Security, any person that under sections 871(h)(2)(B)(ii) and
881(c)(2)(B)(ii) of the Code is considered to be the beneficial owner of that Security.
• “Code” means the U.S. Internal Revenue Code of 1986 as amended. Any reference to any section of the
Code shall mean such section of any successor provisions.
• “Form” means a U.S. Internal Revenue Service form or such successor form as shall be adopted from time
to time by the U.S. Internal Revenue Service and any substantially similar substitute form as may be
permitted by the Code or the regulations thereunder.
• All terms that are used and not defined herein shall have the meanings given to them in the Internal
Revenue Code of 1986 as amended, the regulations issued thereunder, the Qualified Intermediary
Agreement published in Revenue Procedure 2000-12 as amended and Clearstream Banking SA Governing
Documents.
Certification
This statement forms an integral part of the attached withholding certificate. We hereby certify, under penalties of
perjury, that the above information is true, correct and complete and that I am/we are the (an) authorised
representative(s) of the Customer named below.
Name of Clearstream Banking Customer: __________________________________________________________
Address: _____________________________________________________________________________________
____________________________________________________________________________________________
____________________________________________________________________________________________
Customer account number: ______________________________________________________________________
.
Authorised Signature
Authorised Signature
Name
Name
Title
Title
Place
Date
March 2013
A - 38
Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 14. Withholding Statement - NQI Account
With respect to account number(s) __________________________________________________ (the “Account(s)”)
with Clearstream Banking société anonyme, (hereinafter “Clearstream Banking SA”), we hereby certify that with
respect to all U.S. Securities that are, or may be, held in the Account(s) from time to time and to all Reportable
Amounts paid on such U.S. Securities, we are acting as: (tick one box only)

A Non-Qualified Intermediary;
OR

A Non-Withholding Foreign Partnership;
OR

A U.S. branch described in U.S. Treasury Regulations Section 1.1441-1(b)(2)(iv) that is not treated as a U.S.
person.
We have attached hereto a Form W-8IMY duly completed and signed to confirm our intermediary status.
All U.S. Securities that are, or may be, held in the Account(s) from time to time and all Reportable Amounts paid on
such U.S. Securities are held: (tick one box only)

directly by us on behalf of the beneficial owner; or

through another QI, Non-QI, Flow-Through Entity or U.S. Branch, not treated as a U.S. Person and
whose Form W-8IMY is attached;
and are for the account of a recipient that has a segregated account with a single recipient.
NON-U.S. BENEFICIAL OWNER (tick one box only and complete as applicable)

A Non-U.S. Beneficial Owner entitled to the ________% reduced double taxation treaty rate with respect to
Dividends, a tax exemption with respect to Portfolio Interest and a tax exemption for short-term Original
Issue Discount (OID) and bank Certificate of Deposit (CD) interest; or

A Non-U.S. Beneficial Owner entitled to the ________% reduced double taxation treaty rate with respect to
Dividends, a ________% reduced double taxation treaty rate with respect to long-term OID and pre-1984
bond issues, a tax exemption for Portfolio Interest, short-term OID and bank CD Interest; or

A Non-U.S. Beneficial Owner, not claiming the benefit of a U.S. income tax treaty with respect to Dividends
but entitled to a tax exemption for short-term OID and bank CD Interest.
Attached is Form W-8BEN, completed in the name of the Beneficial Owner.
OR

A Non-U.S. Beneficial Owner that is a Foreign Government, International Organisation, Foreign Central
Bank or a Foreign Tax Exempt Organisation (other than a Foreign Private Foundation) entitled to exemption
from Non-Resident Alien (NRA) withholding tax on all Reportable Amounts.
Attached is Form W-8EXP, completed in the name of the Beneficial Owner.
Clearstream Banking
Customer Tax Guide - United States of America
March 2013
A - 39
United States of America - Appendices
Appendix 14 (cont). Withholding Statement - NQI Account
OR

A Non-U.S. Beneficial Owner that is a Foreign Private Foundation, entitled to the reduced 4% withholding
tax rate with respect to Dividends, Interest and long-term OID, and tax exemption for short-term OID and
bank CD Interest; or

A Non-U.S. Beneficial Owner for which all Reportable Amounts constitute Effectively Connected Income
with a trade or business conducted in the U.S.A. are exempt from NRA withholding.
Attached is Form W-8ECI, completed in the name of the Beneficial Owner.
QUALIFIED INTERMEDIARY (QI) (tick one box only and complete as applicable)

A QI that has assumed Primary NRA withholding responsibility and Form 1099 reporting and backup
withholding responsibility; or
or

A QI that has not assumed Primary NRA withholding responsibility and (tick one box only and complete as
applicable):

is receiving all Reportable Amounts exclusively for Non-U.S. Beneficial Owners entitled to _______%
reduced double taxation treaty rate with respect to Dividends and tax exemption for Portfolio
Interest, short-term OID and bank CD Interest; or
or

is receiving all Reportable Amounts exclusively for underlying account holders other than U.S. NonExempt recipients, that are entitled to receive all Reportable Amounts gross of NRA withholding; or
or

is receiving all Reportable Amounts exclusively for Non-U.S. Beneficial Owners that are not
requesting treaty relief with respect to Dividends, but are entitled to a tax exemption for Portfolio
Interest, short-term OID and bank CD Interest; or
or

is receiving all Reportable Amounts on behalf of Foreign Private Foundations entitled to a 4% rate of
NRA withholding tax on Dividends, Interest and long-term OID and a tax exemption for short-term
OID and bank CD Interest; or
or

is receiving all Reportable Amounts exclusively for the account of undocumented account holders,
not recognised as U.S. Non-Exempt recipients and subject to 30% NRA withholding tax on Dividends,
Interest and long-term OID and to the current rate of backup withholding tax on short-term OID and
bank CD Interest; or
or

is receiving all Reportable Amounts on behalf of undisclosed account holders subject to the current
rate of backup withholding tax on all Reportable Amounts.
Attached is Form W-8IMY, completed in the name of our account holder to confirm their intermediary
status.
March 2013
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Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 14 (cont). Withholding Statement - NQI Account
NQI NON-WITHHOLDING FOREIGN PARTNERSHIP OR FOREIGN TRUST

An NQI, Non-Withholding Foreign Partnership or Non-Withholding Trust that is receiving all Reportable
Amounts on behalf of a single benficial owner. (tick one box only and complete as applicable)

A Non-U.S. Beneficial Owner entitled to the ________% reduced double taxation treaty rate with
respect to Dividends, a tax exemption with respect to Portfolio Interest and a tax exemption for shortterm Original Issue Discount (OID) and bank Certificate of Deposit (CD) interest; or

A Non-U.S. Beneficial Owner entitled to the ________% reduced double taxation treaty rate with
respect to Dividends, a ________% reduced double taxation treaty rate with respect to long-term OID
and pre-1984 bond issues, a tax exemption for Portfolio Interest, short-term OID and bank CD
Interest; or

A Non-U.S. Beneficial Owner, not claiming the benefit of a U.S. income tax treaty with respect to
Dividends but entitled to a tax exemption for short-term OID and bank CD Interest; or

A documented U.S. non-exempt recipient for whom we are providing a duly completed Form W-9; or

A documented U.S. exempt recipient for whom we are providing a duly completed Form W-9.
Attached is Form W-8IMY, completed in the name of our account holder to confirm their intermediary status, and
Form W-8BEN, W-8EXP, W-8ECI or W-9, as appropriate, from the beneficial owner.
U.S. PERSON (tick one box only and complete as applicable)

A documented U.S. Non-Exempt recipient for whom we are providing a duly completed Form W-9; or

A documented U.S. Exempt recipient for whom we are providing a duly completed Form W-9; or

An undocumented U.S. Non-Exempt recipient whose name and address are:
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
Clearstream Banking
Customer Tax Guide - United States of America
March 2013
A - 41
United States of America - Appendices
Appendix 14 (cont). Withholding Statement - NQI Account
Notifications
We undertake to notify Clearstream Banking SA at the latest by 10:00 Central European Time two Business Days
prior to any relevant Payment Date of any balance of U.S. Securities that is not covered by this withholding
statement or by the attached IRS Form(s) or documentation.
We hereby undertake to notify Clearstream Banking SA promptly, and at the latest within 30 days, of any changes
to the information included in this withholding statement or the attached forms and documentation to which this
instruction refers.
We hereby undertake to provide Clearstream Banking SA, within its deadline, with any additional statements,
certifications, Forms, documentation or information that may be required under the U.S. Internal Revenue Code
(IRC) or the regulations thereunder.
Reporting
We hereby appoint Clearstream Banking SA and Clearstream Banking SA’s U.S. Tax Reporting Agent as our
attorneys-in-fact with authority to collect and forward any information or documents to the IRS to the extent
required under Section 1.1441 of the IRC as amended and the regulations thereunder.
We similarly appoint them to collect and forward any information or documents to other persons holding the
relevant U.S. Securities for the account of Clearstream Banking SA or from whom Clearstream Banking SA
receives payments on such securities.
We irrevocably authorise Clearstream Banking SA to disclose this certificate or any copy, attachments or related
information to the interested party, in the event of or threat of administrative or legal proceedings, an official inquiry
or request of the U.S. Internal Revenue Service or other relevant authority, in which or to which this withholding
statement (including any certificate, Form, document or other information referred to herein) is, or would be, relevant.
Undertakings
We agree irrevocably that, in the event that:
i) we fail to deliver any certificate, Form or document necessary under the U.S. Internal Revenue Code of 1986
as amended, the regulations issued thereunder, the Qualified Intermediary Agreement published in Revenue
Procedure 2000-12 as amended or Clearstream Banking SA Governing Documents; or
ii) this certificate or any certificate, Form or information referred to herein and delivered by us to Clearstream
Banking SA is incorrect, outdated, incomplete or invalid for any reason within our control or within our knowledge;
then we shall indemnify Clearstream Banking SA for any resulting loss, claim, liability or expense. This includes
penalties and resulting additions to tax and interest thereon (and reasonable expenses of counsel). Moreover,
Clearstream Banking SA may charge our account or otherwise reclaim from us and we will pay Clearstream
Banking SA on demand the amount of such charge or loss and any other expenses incurred by Clearstream
Banking SA in pursuing their claim.
We understand that:
i) If this certificate or any attached or connected certificate, Form or document or any information furnished by
us is found to be false, we may be liable for damages and could also be subject to such other sanctions as
may be determined by the Secretary of the U.S. Department of the Treasury or Internal Revenue Service; and
ii) The U.S. Department of the Treasury or Internal Revenue Service may determine that any certificate or
statement given by us will not be valid to prevent the imposition of the 30% U.S. withholding tax on payments to
us of interest that would otherwise qualify for exemption from such tax as “portfolio interest” within the meaning
of sections 871(h) and 881(c) of the Code. The U.S. Department of the Treasury or IRS may further determine
that any certificate or statement given by us will be ineffectual in the preclusion of or entitlement to a reduction
of the imposition of the 30% U.S. withholding tax on payments to us of dividends within the meaning of the Code.
March 2013
A - 42
Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 14 (cont). Withholding Statement - NQI Account
Definitions
For the purposes of this Withholding Statement:
• “Beneficial Owner” means, with respect to a Security, any person that under sections 871(h)(2)(B)(ii) and
881(c)(2)(B)(ii) of the Code is considered to be the beneficial owner of that Security.
• “Code” means the U.S. Internal Revenue Code of 1986 as amended. Any reference to any section of the
Code shall mean such section of any successor provisions.
• “Form” means a U.S. Internal Revenue Service form or such successor form as shall be adopted from time
to time by the U.S. Internal Revenue Service and any substantially similar substitute form as may be
permitted by the Code or the regulations thereunder.
• All terms that are used and not defined herein shall have the meanings given to them in the Internal
Revenue Code of 1986 as amended, the regulations issued thereunder, the Qualified Intermediary
Agreement published in Revenue Procedure 2000-12 as amended and Clearstream Banking SA Governing
Documents.
Certification
This statement forms an integral part of the attached withholding certificate. We hereby certify, under penalties of
perjury, that the above information is true, correct and complete and that I am/we are the (an) authorised
representative(s) of the Customer named below.
Name of Clearstream Banking Customer: __________________________________________________________
Address: ____________________________________________________________________________________
____________________________________________________________________________________________
____________________________________________________________________________________________
Customer account number: _____________________________________________________________________
.
Authorised Signature
Authorised Signature
Name
Name
Title
Title
Place
Date
Clearstream Banking
Customer Tax Guide - United States of America
March 2013
A - 43
United States of America - Appendices
Appendix 15. U.S. Foreign Targeted Interest Certificate
This statement must be completed by Clearstream Banking's customer, signed by the requisite authorised signatories
and returned (by mail) to Clearstream Banking for the attention of OTL - Tax Services.
We hereby state that:
A. With respect to all of the foreign-targeted obligations of United States issuers that are held by us (such
obligations being identified below (the “Securities”)) and every other such obligation to be acquired and held
by us during the period beginning on the date of this statement and ending on the date the next such
statement is required to be provided:
i) The beneficial owner of each Security will not be a United States person on each interest payment date
while we hold such Security; and
ii) We will provide within 30 days after such interest payment date a United States beneficial ownership
notification to you in accordance with A-15 of Section 35a.9999-5 of the United States Treasury
Regulations in the event this statement is or becomes untrue with respect to any of such Securities.
B. If this is not the first statement that we have sent to you, with respect to each of the Securities that has been
held by us at any time since the date on which the immediately preceding statement was sent to you, that
either:
i) The beneficial owner of each such Security has not been a United States person on each interest payment
date; or
ii) If we are holding or have held a Security on behalf of a beneficial owner and such beneficial owner has
been a United States person on one or more of the following interest payment dates (insert applicable
payment dates), we have forwarded or will forward a United States beneficial ownership notification to
you in accordance with A-15 of Section 35a.9999-5 of the Treasury Regulations; and
C. If we are a Clearing Organisation,
i) We have received from each of our members on whose behalf we hold a Security, a certificate in this form;
and
ii) We will forward to you any United States beneficial ownership notification that we receive from our
members in accordance with A-15 of Section 35a.9999-5 of the Treasury Regulations.
This statement pertains to the following Securities and is valid for any coupons due in the current year:
Nominal value
March 2013
A - 44
Security description
Due date
Currently
held
Held since
(date of last
statement)
Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 15 (cont). U.S. Foreign Targeted Interest Certificate (cont)
For the purposes of the foregoing:
Beneficial Owner of a security means the person who is ultimately entitled to control the income from the security.
It does not include a nominee or any person acting in a similar capacity.
Clearing Organisation means a securities clearing organisation that is in the business of holding securities for
member organisations and transferring securities among such members by credit or debit to the account of a
member without the necessity of physical delivery of the security.
United States Person means an individual who is a citizen or resident of the United States, a corporation,
partnership or other entity created or organised in or under the laws of the United States or an estate or trust that
is subject to United States Federal income taxation without regard to the source of its income.
United States means the United States of America, the Commonwealth of Puerto Rico and each territory and
possession of the United States of America and all areas subject to its jurisdiction.
Foreign-Targeted Obligation means an obligation that is in registered form and was sold or resold in connection
with its original issuance in accordance with procedures reasonably designed to ensure that it would be sold only
outside the United States to a person that is not a United States person (other than a foreign branch of a United
States financial institution). Such obligation, if evidenced by a physical document other than a confirmation receipt,
will contain on its face a legend indicating that it has been sold or resold in connection with its original issuance in
accordance with such procedures.
We understand that this statement is required in connection with certain tax laws and regulations of the United
States. We irrevocably authorise you to produce this statement, or a copy hereof, to any interested party in any
administrative or legal proceedings or official inquiries in connection with which this statement is or would be
relevant, and to deliver any Forms W-9 (or substitutes delivered pursuant hereto) to the appropriate authorities in
compliance with applicable laws and regulations.
For and on behalf of:
Name of Clearstream Banking customer: __________________________________________________________
Full address: _________________________________________________________________________________
____________________________________________________________________________________________
By (authorised signature/s):
.
Authorised Signature
Authorised Signature
Name
Name
Title
Title
Place
Date
Clearstream Banking
Customer Tax Guide - United States of America
March 2013
A - 45
United States of America - Appendices
Appendix 16. Statement to Reclaim U.S. withholding tax
(The original of this document should be sent by registered mail duly completed and signed.)
Clearstream Banking
Attn: OTL - Tax Services
42, avenue J.F. Kennedy
L-1855 Luxembourg
Luxembourg
We are a Clearstream Banking customer and hereby request a reclaim of U.S. withholding tax applied to the income
payment identified below:
Account details:
Customer name: ____________________________________________________________ Account no: __________________
Status (tick one box only):

QI-A Omnibus a

QI-B Omnibus a


NQI

Other: ____________________________________________________________________
QI-C Omnibus a

Proprietary
Reason for reclaim (tick one box only):

Allocation information not provided


Securities not in the certified Account No: ______________________________________________________________
Certification not provided

Pre-payment notice not valid
a. The types of omnibus account are certified as follows:
- QI-A: with primary NRA withholding responsibility and 1099 reporting and backup withholding responsibility;
- QI-B: with primary NRA withholding responsibility but without backup withholding or 1099 reporting responsibility;
- QI-C: without primary NRA withholding or backup withholding or 1099 reporting responsibility.
Tax details:
QI EIN (for QIs):
_____________________________
Security details:
ISIN or Common code:
_____________________________
Name of the issue:
_______________________________________________________________________________
Record date (DD/MM/YYYY):
_____________________________
Payment date:
____________________________
Total holding:
_____________________________
Currency:
____________________________
Payment details: (enter amounts received from Clearstream Banking on payment date)
1. Holding
_____________________________
Gross amount:
_____________________________
Tax amount:
_____________________________
Net amount:
_____________________________
2. Holding
_____________________________
Gross amount:
_____________________________
Tax amount:
_____________________________
Net amount:
_____________________________
March 2013
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Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 16 (cont). Statement to reclaim U.S. withholding tax
Refund requested:
On total holding: ___________________________
Tax rate applied initially: ___________________________
Tax rate to apply: ___________________________
1. On partial holding: ___________________________
Tax rate applied initially: ___________________________
Tax rate to apply: ___________________________
2. On partial holding: ___________________________
Tax rate applied initially: ___________________________
Tax rate to apply: ___________________________
Authorised signatories:
.
Authorised Signature
Authorised Signature
Name
Name
Title
Title
Place
Date
Clearstream Banking
Customer Tax Guide - United States of America
March 2013
A - 47
United States of America - Appendices
Appendix 17. IRS Form 1042-S (Foreign Person's U.S. Source Income
Subject to Withholding) - 2008
Form
1042-S
Department of the Treasury
Internal Revenue Service
Foreign Person’s U.S. Source Income
Subject to Withholding
AMENDED
1 Income 2 Gross income
code
3 Withholding
allowances
2008
PRO-RATA BASIS REPORTING
4 Net income
5 Tax
rate
OMB No. 1545-0096
Copy A for
Internal Revenue Service
6 Exemption 7 Federal tax withheld
code
8 Withholding by other agents
9 Total withholding credit
10 Amount repaid to recipient
11 Withholding agent’s EIN
EIN
12a WITHHOLDING AGENT’S name
14
Recipient’s U.S. TIN, if any
15
SSN or ITIN
EIN
Recipient’s foreign tax identifying number, if any
QI-EIN
16 Country code
17
NQI’s/FLOW-THROUGH ENTITY’S name
18 Country code
QI-EIN
12b Address (number and street)
19a NQI’s/Entity’s address (number and street)
12c Additional address line (room or suite no.)
19b Additional address line (room or suite no.)
12d City or town, province or state, country, ZIP or foreign postal code
19c City or town, province or state, country, ZIP or foreign postal code
13b Recipient code 20
13a RECIPIENT’S name
NQI’s/Entity’s U.S. TIN, if any
13c Address (number and street)
21
PAYER’S name and TIN (if different from withholding agent’s)
13d Additional address line (room or suite no.)
22
Recipient account number (optional)
13e City or town, province or state, country, ZIP or foreign postal code
23
State income tax withheld 24 Payer’s state tax no. 25 Name of state
For Privacy Act and Paperwork Reduction Act Notice, see page 16 of the separate instructions.
Form
1042-S
Department of the Treasury
Internal Revenue Service
Foreign Person’s U.S. Source Income
Subject to Withholding
AMENDED
1 Income 2 Gross income
code
3 Withholding
allowances
Cat. No. 11386R
2008
Form
5 Tax
rate
(2008)
OMB No. 1545-0096
PRO-RATA BASIS REPORTING
4 Net income
1042-S
Copy B
for Recipient
6 Exemption 7 Federal tax withheld
code
8 Withholding by other agents
9 Total withholding credit
10 Amount repaid to recipient
11 Withholding agent’s EIN
EIN
12a WITHHOLDING AGENT’S name
14
Recipient’s U.S. TIN, if any
15
SSN or ITIN
EIN
Recipient’s foreign tax identifying number, if any
QI-EIN
16 Country code
17
NQI’s/FLOW-THROUGH ENTITY’S name
18 Country code
QI-EIN
12b Address (number and street)
19a NQI’s/Entity’s address (number and street)
12c Additional address line (room or suite no.)
19b Additional address line (room or suite no.)
12d City or town, province or state, country, ZIP or foreign postal code
19c City or town, province or state, country, ZIP or foreign postal code
13a RECIPIENT’S name
13b Recipient code 20
NQI’s/Entity’s U.S. TIN, if any
13c Address (number and street)
21
PAYER’S name and TIN (if different from withholding agent’s)
13d Additional address line (room or suite no.)
22
Recipient account number (optional)
13e City or town, province or state, country, ZIP or foreign postal code
23
State income tax withheld 24 Payer’s state tax no. 25 Name of state
For Privacy Act and Paperwork Reduction Act Notice, see page 16 of the separate instructions.
March 2013
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Cat. No. 11386R
Form
1042-S
(2008)
Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 17 (cont). IRS Form 1042-S (Foreign Person's U.S. Source Income Subject to
Withholding) - 2008
Por regla general, todo extranjero no residente, todo organismo
fideicomisario extranjero no residente y toda sociedad anónima
extranjera que reciba ingresos en los Estados Unidos, incluyendo
ingresos relacionados con la conducción de un negocio o comercio
dentro de los Estados Unidos, deberá presentar una declaración
estadounidense de impuestos sobre ingreso. Sin embargo, no se
requiere declaración alguna a un individuo extranjero, una sociedad
anónima extranjera u organismo fideicomisario extranjero no
residente, si tal persona no ha efectuado comercio o negocio en los
Estados Unidos durante el año fiscal y si la responsabilidad con los
impuestos de tal persona ha sido satisfecha plenamente mediante
retencion del impuesto de los Estados Unidos en la fuente. (Las
sociedades anónimas envian la Forma 1120-F; todos los demás
contribuyentes envian la Forma 1040NR (o la Forma 1040NR-EZ si le
corresponde).) Se podrán obtener formas e instrucciones en
cualquier Embajada o Consulado de los Estados Unidos o
escribiendo directamente a: National Distribution Center,
P.O. Box 8903, Bloomington, IL 61702-8903, U.S.A.
U.S. Income Tax Filing Requirements
Generally, every nonresident alien individual, nonresident alien
fiduciary, and foreign corporation with United States income,
including income that is effectively connected with the conduct of a
trade or business in the United States, must file a United States
income tax return. However, no return is required to be filed by a
nonresident alien individual, nonresident alien fiduciary, or a foreign
corporation if such person was not engaged in a trade or business in
the United States at any time during the tax year and if the tax
liability of such person was fully satisfied by the withholding of
United States tax at the source. (Corporations file Form 1120-F; all
others file Form 1040NR (or Form 1040NR-EZ if eligible).) You may
get the return forms and instructions at any United States Embassy
or consulate or by writing to: National Distribution Center, P.O. Box
8903, Bloomington, IL 61702-8903, U.S.A.
En règle générale, tout étranger non-résident, tout organisme
fidéicommissaire étranger non-résident et toute société étrangère
percevant un revenu aux Etats-Unis, y compris tout revenu dérivé,
en fait, du fonctionnement d’un commerce ou d’une affaire aux
Etats-Unis, doit soumettre aux Etats-Unis, une déclaration d’impôt
sur le revenu. Cependant aucune déclaration d’impôt sur le revenu
n’est exigée d’un étranger non-résident, d’un organisme
fidéicommissaire étrange non-résident, ou d’une société étrangère
s’ils n’ont pris part à aucun commerce ou affaire aux Etats-Unis à
aucun moment pendant l’année fiscale et si les impôts dont ils sont
redevables, ont été entièrement acquittés par une retenue à la
source, de leur montant. (Les sociétés doivent faire leur déclaration
d’impôt en remplissant le formulaire 1120-F; tous les autres
redevables doivent remplir le formulaire 1040NR (ou 1040NR-EZ si
éligible).) On peut se procurer formulaires de déclarations d’impôts et
instructions dans toutes les Ambassades et tous les Consulats des
Etats-Unis. L’on peut également s’adresser pour tous
renseignements a: National Distribution Center, P.O. Box 8903,
Bloomington, IL 61702-8903, U.S.A.
Form
1042-S
Department of the Treasury
Internal Revenue Service
Im allgemeinen muss jede ausländische Einzelperson, jeder
ausländische Bevollmächtigte und jede ausländische Gesellschaft mit
Einkommen in den Vereinigten Staaten, einschliesslich des
Einkommens, welches direkt mit der Ausübung von Handel oder
Gewerbe innerhalb der Staaten verbunden ist, eine
Einkommensteuererklärung der Vereinigten Staaten abgeben. Eine
Erklärung, muss jedoch nicht von Ausländern, ausländischen
Bevollmächtigten oder ausländischen Gesellschaften in den
Vereinigten Staaten eingereicht werden, falls eine solche Person
während des Steuerjahres kein Gewerbe oder Handel in den
Vereinigten Staaten ausgeübt hat und die Steuerschuld durch
Einbehaltung der Steuern der Vereinigten Staaten durch die
Einkommensquelle abgegolten ist. (Gesellschaften reichen den
Vordruck 1120-F ein; alle anderen reichen das Formblatt 1040NR
oder wenn passend das Formblatt 1040NR-EZ ein.)
Einkommensteuererklärungen und Instruktionen können bei den
Botschaften und Konsulaten der Vereiningten Staaten eingeholt
werden. Um weitere Informationen wende man sich bitte an: National
Distribution Center, P.O. Box 8903, Bloomington, IL 61702-8903,
U.S.A.
Foreign Person’s U.S. Source Income
Subject to Withholding
AMENDED
1 Income 2 Gross income
code
3 Withholding
allowances
2008
PRO-RATA BASIS REPORTING
4 Net income
5 Tax
rate
OMB No. 1545-0096
Copy C
for Recipient
Attach to any Federal tax return you file
6 Exemption 7 Federal tax withheld
code
8 Withholding by other agents
9 Total withholding credit
10 Amount repaid to recipient
11 Withholding agent’s EIN
EIN
12a WITHHOLDING AGENT’S name
14
Recipient’s U.S. TIN, if any
15
SSN or ITIN
EIN
Recipient’s foreign tax identifying number, if any
QI-EIN
16 Country code
17
NQI’s/FLOW-THROUGH ENTITY’S name
18 Country code
QI-EIN
12b Address (number and street)
19a NQI’s/Entity’s address (number and street)
12c Additional address line (room or suite no.)
19b Additional address line (room or suite no.)
12d City or town, province or state, country, ZIP or foreign postal code
19c City or town, province or state, country, ZIP or foreign postal code
13a RECIPIENT’S name
13b Recipient code 20
NQI’s/Entity’s U.S. TIN, if any
13c Address (number and street)
21
PAYER’S name and TIN (if different from withholding agent’s)
13d Additional address line (room or suite no.)
22
Recipient account number (optional)
13e City or town, province or state, country, ZIP or foreign postal code
23
State income tax withheld 24 Payer’s state tax no. 25 Name of state
For Privacy Act and Paperwork Reduction Act Notice, see page 16 of the separate instructions.
Clearstream Banking
Customer Tax Guide - United States of America
Cat. No. 11386R
Form
1042-S
(2008)
March 2013
A - 49
United States of America - Appendices
Appendix 17 (cont). IRS Form 1042-S (Foreign Person's U.S. Source Income Subject to
Withholding) - 2008
Explanation of Codes
Box 6. Exemption code (applies if the tax rate entered in box 5 is 00.00).
Code
Authority for Exemption
01
Income effectively connected with a U.S. trade or business
02
Exempt under an Internal Revenue Code section (income other than
portfolio interest)
4
03
Income is not from U.S. sources
04
Exempt under tax treaty
05
Portfolio interest exempt under an Internal Revenue Code section
06
Qualified intermediary that assumes primary withholding responsibility
07
Withholding foreign partnership or withholding foreign trust
08
U.S. branch treated as a U.S. person
09
Qualified intermediary represents income is exempt
Other
Dividend
Interest
Box 1. Income code.
Types of Income
Code
01 Interest paid by U.S. obligors—general
02 Interest paid on real property mortgages
03 Interest paid to controlling foreign corporations
04 Interest paid by foreign corporations
05 Interest on tax-free covenant bonds
29 Deposit interest
30 Original issue discount (OID)
31 Short-term OID
33 Substitute payment—interest
06
07
08
34
Dividends paid by U.S. corporations—general
Dividends qualifying for direct dividend rate
Dividends paid by foreign corporations
Substitute payment—dividends
09
10
11
12
13
14
15
16
17
18
19
20
24
25
26
Capital gains
Industrial royalties
Motion picture or television copyright royalties
Other royalties (for example, copyright, recording, publishing)
Real property income and natural resources royalties
Pensions, annuities, alimony, and/or insurance premiums
Scholarship or fellowship grants
Compensation for independent personal services1
1
Compensation for dependent personal services
Compensation for teaching1
1
Compensation during studying and training
2
Earnings as an artist or athlete
Real estate investment trust (REIT) distributions of capital gains
Trust distributions subject to IRC section 1445
Unsevered growing crops and timber distributions by a trust subject
to IRC section 1445
Publicly traded partnership distributions subject to IRC section 1446
6
Gambling winnings
3
Notional principal contract income
Substitute payment—other
Capital gains distributions
Return of capital
Other income
27
28
32
35
36
37
50
Box 12. Recipient code.
Code
Type of Recipient
Individual2
01
2
Corporation
02
Partnership other than withholding foreign partnership2
03
04
Withholding foreign partnership or withholding foreign trust
05
Trust
06
Government or international organization
07
Tax-exempt organization (IRC section 501(a))
08
Private foundation
2
09
Artist or athlete
10
Estate
11
U.S. branch treated as U.S. person
Qualified intermediary
12
5
Private arrangement intermediary withholding rate pool—general
13
14
Private arrangement intermediary withholding rate pool—
5
exempt organizations
15
Qualified intermediary withholding rate pool—general5
Qualified intermediary withholding rate pool—exempt organizations5
16
17
Authorized foreign agent
18
Public pension fund
20
Unknown recipient
1
If compensation that otherwise would be covered under Income Codes 16–19 is directly attributable to the recipient’s occupation as an artist or athlete, use Income Code 20 instead.
If Income Code 20 is used, Recipient Code 09 (artist or athlete) should be used instead of Recipient Code 01 (individual), 02 (corporation), or 03 (partnership other than withholding foreign
partnership).
Use appropriate Interest Income Code for embedded interest in a notional principal contract.
4
Non-U.S. source income received by a nonresident alien is not subject to U.S. tax. Use Exemption Code 03 when entering an amount for information reporting purposes only.
5
May be used only by a qualified intermediary.
6
Subject to 30% withholding rate unless the recipient is from one of the treaty countries listed under Gambling winnings (Income Code 28) in Pub. 515.
2
3
Form
1042-S
Department of the Treasury
Internal Revenue Service
Foreign Person’s U.S. Source Income
Subject to Withholding
AMENDED
1 Income 2 Gross income
code
3 Withholding
allowances
2008
PRO-RATA BASIS REPORTING
4 Net income
5 Tax
rate
OMB No. 1545-0096
Copy D
for Recipient
Attach to any state tax return you file
6 Exemption 7 Federal tax withheld
code
8 Withholding by other agents
9 Total withholding credit
10 Amount repaid to recipient
11 Withholding agent’s EIN
EIN
12a WITHHOLDING AGENT’S name
14
Recipient’s U.S. TIN, if any
15
SSN or ITIN
EIN
Recipient’s foreign tax identifying number, if any
QI-EIN
16 Country code
17
NQI’s/FLOW-THROUGH ENTITY’S name
18 Country code
QI-EIN
12b Address (number and street)
19a NQI’s/Entity’s address (number and street)
12c Additional address line (room or suite no.)
19b Additional address line (room or suite no.)
12d City or town, province or state, country, ZIP or foreign postal code
19c City or town, province or state, country, ZIP or foreign postal code
13a RECIPIENT’S name
13b Recipient code 20
NQI’s/Entity’s U.S. TIN, if any
13c Address (number and street)
21
PAYER’S name and TIN (if different from withholding agent’s)
13d Additional address line (room or suite no.)
22
Recipient account number (optional)
13e City or town, province or state, country, ZIP or foreign postal code
23
State income tax withheld 24 Payer’s state tax no. 25 Name of state
For Privacy Act and Paperwork Reduction Act Notice, see page 16 of the separate instructions.
March 2013
A - 50
Cat. No. 11386R
Form
1042-S
(2008)
Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 17 (cont). IRS Form 1042-S (Foreign Person's U.S. Source Income Subject to
Withholding) - 2008
Form
1042-S
Department of the Treasury
Internal Revenue Service
Foreign Person’s U.S. Source Income
Subject to Withholding
AMENDED
1 Income 2 Gross income
code
3 Withholding
allowances
2008
PRO-RATA BASIS REPORTING
4 Net income
5 Tax
rate
OMB No. 1545-0096
Copy E
for Withholding Agent
6 Exemption 7 Federal tax withheld
code
8 Withholding by other agents
9 Total withholding credit
10 Amount repaid to recipient
11 Withholding agent’s EIN
EIN
12a WITHHOLDING AGENT’S name
14
Recipient’s U.S. TIN, if any
15
SSN or ITIN
EIN
Recipient’s foreign tax identifying number, if any
QI-EIN
16 Country code
17
NQI’s/FLOW-THROUGH ENTITY’S name
18 Country code
QI-EIN
12b Address (number and street)
19a NQI’s/Entity’s address (number and street)
12c Additional address line (room or suite no.)
19b Additional address line (room or suite no.)
12d City or town, province or state, country, ZIP or foreign postal code
19c City or town, province or state, country, ZIP or foreign postal code
13a RECIPIENT’S name
13b Recipient code 20
NQI’s/Entity’s U.S. TIN, if any
13c Address (number and street)
21
PAYER’S name and TIN (if different from withholding agent’s)
13d Additional address line (room or suite no.)
22
Recipient account number (optional)
13e City or town, province or state, country, ZIP or foreign postal code
23
State income tax withheld 24 Payer’s state tax no. 25 Name of state
For Privacy Act and Paperwork Reduction Act Notice, see page 16 of the separate instructions.
Clearstream Banking
Customer Tax Guide - United States of America
Cat. No. 11386R
Form
1042-S
(2008)
March 2013
A - 51
United States of America - Appendices
Appendix 18. IRS Form 1099 INT (U.S. Person's U.S. Source Income Subject
to Withholding) - 2008
Attention:
This form is provided for informational purposes only. Copy A appears in red,
similar to the official IRS form. Do not file copy A with the IRS. The official printed
version of this IRS form is scannable, but the online version of it, printed from this
website, is not. A penalty of $50 per information return may be imposed for filing
forms that cannot be scanned.
To order official IRS forms, call 1-800-TAX-FORM (1-800-829-3676) or
Order Information Returns and Employer Returns Online, and we’ll mail you the
scannable forms and other products.
See IRS Publications 1141, 1167, 1179 and other IRS resources for information
about printing these tax forms.
9292
VOID
CORRECTED
PAYER’S name, street address, city, state, ZIP code, and telephone no.
Payer’s RTN (optional)
OMB No. 1545-0112
2009
1 Interest income
$
Interest Income
2 Early withdrawal penalty
$
PAYER’S federal identification number
RECIPIENT’S identification number
Form
1099-INT
3 Interest on U.S. Savings Bonds and Treas. obligations
$
RECIPIENT’S name
4 Federal income tax withheld
$
$
Street address (including apt. no.)
6 Foreign tax paid
7 Foreign country or U.S.
possession
City, state, and ZIP code
8 Tax-exempt interest
9 Specified private activity
bond interest
$
$
$
Account number (see instructions)
Form
1099-INT
2nd TIN not.
Cat. No. 14410K
Do Not Cut or Separate Forms on This Page
March 2013
A - 52
5 Investment expenses
—
Copy A
For
Internal Revenue
Service Center
File with Form 1096.
For Privacy Act
and Paperwork
Reduction Act
Notice, see the
2009 General
Instructions for
Forms 1099,
1098, 3921, 3922,
5498, and W-2G.
Department of the Treasury - Internal Revenue Service
Do Not Cut or Separate Forms on This Page
Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 18 (cont). IRS Form 1099 INT (U.S. Person's U.S. Source Income Subject to
Withholding) - 2008
CORRECTED (if checked)
PAYER’S name, street address, city, state, ZIP code, and telephone no.
Payer’s RTN (optional)
OMB No. 1545-0112
2009
1 Interest income
$
Interest Income
2 Early withdrawal penalty
$
PAYER’S federal identification number
RECIPIENT’S identification number
Form
1099-INT
3 Interest on U.S. Savings Bonds and Treas. obligations
$
RECIPIENT’S name
4 Federal income tax withheld
$
$
Street address (including apt. no.)
6 Foreign tax paid
7 Foreign country or U.S.
possession
City, state, and ZIP code
8 Tax-exempt interest
9 Specified private activity
bond interest
$
$
$
5 Investment expenses
Account number (see instructions)
Form
1099-INT
Copy B
For Recipient
(keep for your records)
This is important tax
information and is
being furnished to the
Internal Revenue
Service. If you are
required to file a return,
a negligence penalty or
other sanction may be
imposed on you if this
income is taxable and
the IRS determines that
it has not been
reported.
Department of the Treasury - Internal Revenue Service
Instructions for Recipient
Account number. May show an account or other unique number the
payer assigned to distinguish your account.
Box 1. Shows taxable interest paid to you during the calendar year
by the payer. This does not include interest shown in box 3. May
also show the total amount of the credits from clean renewable
energy bonds, Gulf tax credit bonds, qualified forestry conservation
bonds, new clean renewable energy bonds, qualified energy
conservation bonds, qualified zone academy bonds, and Midwestern
tax credit bonds that must be included in your interest income.
These amounts were treated as paid to you during 2009 on the
credit allowance dates (March 15, June 15, September 15, and
December 15). For more information, see Form 8912, Credit to
Holders of Tax Credit Bonds.
Box 2. Shows interest or principal forfeited because of early withdrawal of time savings. You may deduct this amount to figure your
adjusted gross income on your income tax return. See the instructions for Form 1040 to see where to take the deduction.
Box 3. Shows interest on U.S. Savings Bonds, Treasury bills, Treasury bonds, and Treasury notes. This may or may not all be taxable.
See Pub. 550. This interest is exempt from state and local income
taxes. This interest is not included in box 1.
Box 4. Shows backup withholding. Generally, a payer must backup
withhold at a 28% rate if you did not furnish your taxpayer identification number (TIN) or you did not furnish the correct TIN to the
payer. See Form W-9. Include this amount on your income tax return
as tax withheld.
Clearstream Banking
Customer Tax Guide - United States of America
Box 5. Any amount shown is your share of investment expenses of a
single-class REMIC. If you file Form 1040, you may deduct these
expenses on the “Other expenses” line of Schedule A (Form 1040)
subject to the 2% limit. This amount is included in box 1.
Box 6. Shows foreign tax paid. You may be able to claim this tax as
a deduction or a credit on your Form 1040. See your Form 1040
instructions.
Box 8. Shows tax-exempt interest, including exempt-interest
dividends from a mutual fund or other regulated investment
company, paid to you during the calendar year by the payer. Report
this amount on line 8b of Form 1040 or Form 1040A. This amount
may be subject to backup withholding. See box 4.
Box 9. Shows tax-exempt interest subject to the alternative minimum
tax. This amount is included in box 8. See the Instructions for Form
6251.
Nominees. If this form includes amounts belonging to another
person(s), you are considered a nominee recipient. Complete a Form
1099-INT for each of the other owners showing the income allocable
to each. File Copy A of the form with the IRS. Furnish Copy B to
each owner. List yourself as the “payer” and the other owner(s) as
the “recipient.” File Form(s) 1099-INT with Form 1096 with the
Internal Revenue Service Center for your area. On Form 1096 list
yourself as the “filer.” A husband or wife is not required to file a
nominee return to show amounts owned by the other.
March 2013
A - 53
United States of America - Appendices
Appendix 18 (cont). IRS Form 1099 INT (U.S. Person's U.S. Source Income Subject to
Withholding) - 2008
VOID
CORRECTED
PAYER’S name, street address, city, state, ZIP code, and telephone no.
Payer’s RTN (optional)
OMB No. 1545-0112
2009
1 Interest income
$
Interest Income
2 Early withdrawal penalty
$
PAYER’S federal identification number
RECIPIENT’S identification number
Form
1099-INT
3 Interest on U.S. Savings Bonds and Treas. obligations
$
RECIPIENT’S name
Street address (including apt. no.)
4 Federal income tax withheld
5 Investment expenses
$
$
6 Foreign tax paid
7 Foreign country or U.S.
possession
$
City, state, and ZIP code
Account number (see instructions)
Form
8 Tax-exempt interest
9 Specified private activity
bond interest
$
$
2nd TIN not.
1099-INT
Copy C
For Payer
For Privacy Act
and Paperwork
Reduction Act
Notice, see the
2009 General
Instructions for
Forms 1099,
1098, 3921, 3922,
5498, and W-2G.
Department of the Treasury - Internal Revenue Service
Instructions for Payers
General and specific form instructions are provided as
separate products. The products you should use to complete
Form 1099-INT are the 2009 General Instructions for Forms
1099, 1098, 3921, 3922, 5498, and W-2G and the 2009
Instructions for Forms 1099-INT and 1099-OID. To order
these instructions and additional forms, visit the IRS website
at www.irs.gov, or call 1-800-TAX-FORM (1-800-829-3676).
Caution: Because paper forms are scanned during
processing, you cannot file with the IRS Forms 1096, 1098,
1099, 3921, 3922, or 5498 that you print from the IRS
website.
Due dates. Furnish Copy B of this form to the recipient by
February 1, 2010.
File Copy A of this form with the IRS by March 1, 2010. If
you file electronically, the due date is March 31, 2010. To file
electronically, you must have software that generates a file
according to the specifications in Pub. 1220, Specifications
for Filing Forms 1098, 1099, 3921, 3922, 5498, and W-2G
Electronically. IRS does not provide a fill-in form option.
March 2013
A - 54
Forms 1099-INT and 1098. If you received mortgage interest
in the course of your trade or business, you may have to
report it to the payer of such mortgage interest and to the
IRS on Form 1098, Mortgage Interest Statement. Do not
report mortgage interest to the payer on Form 1099-INT. See
the instructions for Form 1098 for information on reporting
mortgage interest.
Foreign recipient. If the recipient is a nonresident alien, you
may have to withhold federal income tax and file Form
1042-S, Foreign Person’s U.S. Source Income Subject to
Withholding. See the Instructions for Form 1042-S and Pub.
515, Withholding of Tax on Nonresident Aliens and Foreign
Entities.
Need help? If you have questions about reporting on Form
1099-INT, call the information reporting customer service site
toll free at 1-866-455-7438 or 304-263-8700 (not toll free).
For TTY/TDD equipment, call 304-267-3367 (not toll free).
Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 19. IRS Form 1099 - DIV (U.S. Person's U.S. Source Income
Subject to Withholding - Dividend Income) - 2008
Attention:
This form is provided for informational purposes only. Copy A appears in red,
similar to the official IRS form. Do not file copy A with the IRS. The official printed
version of this IRS form is scannable, but the online version of it, printed from this
website, is not. A penalty of $50 per information return may be imposed for filing
forms that cannot be scanned.
To order official IRS forms, call 1-800-TAX-FORM (1-800-829-3676) or
Order Information Returns and Employer Returns Online, and we’ll mail you the
scannable forms and other products.
See IRS Publications 1141, 1167, 1179 and other IRS resources for information
about printing these tax forms.
9191
VOID
CORRECTED
1a Total ordinary dividends
PAYER’S name, street address, city, state, ZIP code, and telephone no.
OMB No. 1545-0110
$
2008
1b Qualified dividends
$
PAYER’S federal identification
number
Form
Dividends and
Distributions
1099-DIV
2a Total capital gain distr.
2b Unrecap. Sec. 1250 gain
$
$
2c Section 1202 gain
2d Collectibles (28%) gain
RECIPIENT’S identification
number
Copy A
For
Internal Revenue
Service Center
File with Form 1096.
RECIPIENT’S name
$
$
3
Nondividend distributions
4 Federal income tax withheld
$
$
Street address (including apt. no.)
5 Investment expenses
$
City, state, and ZIP code
6
Foreign tax paid
7 Foreign country or U.S. possession
Cash liquidation
distributions
9 Noncash liquidation
distributions
$
Account number (see instructions)
2nd TIN not.
8
$
Form
1099-DIV
Clearstream Banking
Customer Tax Guide - United States of America
$
Cat. No. 14415N
Do Not Cut or Separate Forms on This Page
For Privacy Act
and Paperwork
Reduction Act
Notice, see the
2008 General
Instructions for
Forms 1099,
1098, 5498,
and W-2G.
—
Department of the Treasury - Internal Revenue Service
Do Not Cut or Separate Forms on This Page
March 2013
A - 55
United States of America - Appendices
Appendix 19 (cont). IRS Form 1099 - DIV (U.S. Person's U.S. Source Income Subject to
Withholding - Dividend Income) - 2008
CORRECTED (if checked)
PAYER’S name, street address, city, state, ZIP code, and telephone no.
1a Total ordinary dividends
OMB No. 1545-0110
2008
$
1b Qualified dividends
$
PAYER’S federal identification
number
Form
1099-DIV
2a Total capital gain distr.
2b Unrecap. Sec. 1250 gain
$
$
2c Section 1202 gain
2d Collectibles (28%) gain
$
$
3
Nondividend distributions
4 Federal income tax withheld
$
$
Street address (including apt. no.)
5 Investment expenses
$
City, state, and ZIP code
6
Foreign tax paid
7 Foreign country or U.S. possession
Cash liquidation
distributions
9 Noncash liquidation
distributions
$
8
Account number (see instructions)
$
1099-DIV
(keep for your records)
Instructions for Recipients
What’s New? The 5% capital gains rate is reduced to zero after
December 31, 2007. See box 1b.
Account number. May show an account or other unique number the
payer assigned to distinguish your account.
Box 1a. Shows total ordinary dividends that are taxable. Include this
amount on line 9a of Form 1040 or 1040A. Also, report it on
Schedule B (Form 1040) or Schedule 1 (Form 1040A), if required.
The amount shown may be a distribution from an employee stock
ownership plan (ESOP). Report it as a dividend on your Form
1040/1040A but treat it as a plan distribution, not as investment
income, for any other purpose.
Box 1b. Shows the portion of the amount in box 1a that may be
eligible for the 15% or zero capital gains rates. See the Form
1040/1040A instructions for how to determine this amount. Report
the eligible amount on line 9b, Form 1040 or 1040A.
Box 2a. Shows total capital gain distributions from a regulated
investment company or real estate investment trust. Report the
amounts shown in box 2a on Schedule D (Form 1040), line 13. But, if
no amount is shown in boxes 2c–2d and your only capital gains and
losses are capital gain distributions, you may be able to report the
amounts shown in box 2a on line 13 of Form 1040 (line 10 of Form
1040A) rather than Schedule D. See the Form 1040/1040A
instructions.
Box 2b. Shows the portion of the amount in box 2a that is
unrecaptured section 1250 gain from certain depreciable real
property. Report this amount on the Unrecaptured Section 1250
Gain Worksheet–Line 19 in the Schedule D instructions (Form 1040).
Box 2c. Shows the portion of the amount in box 2a that is section
1202 gain from certain small business stock that may be subject to a
50% exclusion. See the Schedule D (Form 1040) instructions.
March 2013
A - 56
Copy B
For Recipient
RECIPIENT’S identification
number
RECIPIENT’S name
Form
Dividends and
Distributions
$
This is important
tax information
and is being
furnished to the
Internal Revenue
Service. If you
are required to
file a return, a
negligence
penalty or other
sanction may be
imposed on you
if this income is
taxable and the
IRS determines
that it has not
been reported.
Department of the Treasury - Internal Revenue Service
Box 2d. Shows 28% rate gain from sales or exchanges of
collectibles. If required, use this amount when completing the 28%
Rate Gain Worksheet–Line 18 in the instructions for Schedule D
(Form 1040).
Box 3. Shows the part of the distribution that is nontaxable because
it is a return of your cost (or other basis). You must reduce your cost
(or other basis) by this amount for figuring gain or loss when you sell
your stock. But if you get back all your cost (or other basis), report
future distributions as capital gains. See Pub. 550, Investment
Income and Expenses.
Box 4. Shows backup withholding. For example, a payer must
backup withhold on certain payments at a 28% rate if you did not
give your taxpayer identification number to the payer. See Form W-9,
Request for Taxpayer Identification Number and Certification, for
information on backup withholding. Include this amount on your
income tax return as tax withheld.
Box 5. Shows your share of expenses of a nonpublicly offered
regulated investment company, generally a nonpublicly offered
mutual fund. If you file Form 1040, you may deduct these expenses
on the “Other expenses” line on Schedule A (Form 1040) subject to
the 2% limit. This amount is included in box 1a.
Box 6. Shows the foreign tax that you may be able to claim as a
deduction or a credit on Form 1040. See the Form 1040 instructions.
Box 7. This box should be left blank if a regulated investment
company reported the foreign tax shown in box 6.
Boxes 8 and 9. Shows cash and noncash liquidation distributions.
Nominees. If this form includes amounts belonging to another
person, you are considered a nominee recipient. You must file Form
1099-DIV with the IRS for each of the other owners to show their
share of the income, and you must furnish a Form 1099-DIV to each.
A husband or wife is not required to file a nominee return to show
amounts owned by the other. See the 2008 General Instructions for
Forms 1099, 1098, 5498, and W-2G.
Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 19 (cont). IRS Form 1099 - DIV (U.S. Person's U.S. Source Income Subject to
Withholding - Dividend Income) - 2008
VOID
CORRECTED
PAYER’S name, street address, city, state, ZIP code, and telephone no.
1a Total ordinary dividends
OMB No. 1545-0110
$
2008
1b Qualified dividends
$
PAYER’S federal identification
number
Form
1099-DIV
2a Total capital gain distr.
2b Unrecap. Sec. 1250 gain
$
$
2c Section 1202 gain
2d Collectibles (28%) gain
$
$
Copy C
For Payer
RECIPIENT’S identification
number
RECIPIENT’S name
3
Nondividend distributions
$
4 Federal income tax withheld
$
Street address (including apt. no.)
5 Investment expenses
$
City, state, and ZIP code
6
Foreign tax paid
7 Foreign country or U.S. possession
Cash liquidation
distributions
9 Noncash liquidation
distributions
$
Account number (see instructions)
2nd TIN not.
8
$
Form
Dividends and
Distributions
1099-DIV
For Privacy Act
and Paperwork
Reduction Act
Notice, see the
2008 General
Instructions
for Forms
1099, 1098,
5498,
and W-2G.
$
Department of the Treasury - Internal Revenue Service
Instructions for Payers
General and specific form instructions are provided as
separate products. The products you should use to
complete Form 1099-DIV are the 2008 General
Instructions for Forms 1099, 1098, 5498, and W-2G
and the 2008 Instructions for Form 1099-DIV. A chart
in the general instructions gives a quick guide to which
form must be filed to report a particular payment. To
order these instructions and additional forms, visit the
IRS website at www.irs.gov or call 1-800-TAX-FORM
(1-800-829-3676).
Caution: Because paper for ms are scanned dur ing
processing, you cannot file with the IRS For ms 1096,
1098, 1099, or 5498 that you pr int from the IRS
website.
Due dates. Furnish Copy B of this form to the
recipient by February 2, 2009.
File Copy A of this form with the IRS by
March 2, 2009. If you file electronically, the due date is
March 31, 2009. To file electronically, you must have
Clearstream Banking
Customer Tax Guide - United States of America
software that generates a file according to the
specifications in Pub. 1220, Specifications for Filing
Forms 1098, 1099, 5498, and W-2G Electronically. IRS
does not provide a fill-in form option.
Foreign dividend recipient. If the recipient of the
dividend is a nonresident alien, you may have to
withhold federal income tax and file Form 1042-S,
Foreign Person’s U.S. Source Income Subject to
Withholding. See the Instructions for Form 1042-S and
Pub. 515, Withholding of Tax on Nonresident Aliens
and Foreign Entities.
Need help? If you have questions about reporting on
Form 1099-DIV, call the information reporting customer
service site toll free at 1-866-455-7438 or
304-263-8700 (not toll free). For TTY/TDD equipment,
call 304-267-3367 (not toll free). The hours of operation
are Monday through Friday from 8:30 a.m. to 4:30
p.m., Eastern time.
March 2013
A - 57
United States of America - Appendices
Appendix 20. Customer Waiver Clause Letter
(Customer's letterhead)
Clearstream Banking
Attn: OTL - Tax Services
42, avenue J.F. Kennedy
L-1855 Luxembourg
Luxembourg
Date:
__________________________
Account:
__________________________
The undersigned Clearstream Banking Customer hereby undertakes to deliver to its underlying customer/s the IRS
Form 1099 report/s on behalf of Clearstream Banking on or before 31 January _______________. The Clearstream
Banking Customer hereby agrees to be bound by such obligation and to indemnify, exonerate and hold Clearstream
Banking harmless from and against any and all actions suits, losses, costs, liabilities, damages and expenses
(including reasonable legal fees and disbursements) and interest and penalties assessed by the IRS incurred by
Clearstream Banking as a result of the customer's failure to deliver the tax report on a timely basis.
Name of Clearstream Banking Customer: __________________________________________________________
Address: _____________________________________________________________________________________
____________________________________________________________________________________________
____________________________________________________________________________________________
Yours faithfully,
.
Authorised Signature
Authorised Signature
Name
Name
Title
Title
Place
Date
March 2013
A - 58
Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 21. IRS Form 945 (Annual Return of Withheld Federal Income
Tax)
Form
945
Annual Return of Withheld Federal Income Tax
OMB No. 1545-1430
Department of the Treasury
Internal Revenue Service
Enter state code
for state in
which deposits
were made only
if different from
state in address
to the right (see the
instructions).
For withholding reported on Forms 1099 and W-2G.
See separate instructions. For more information on income tax withholding, see Pub. 15 (Circ. E) and Pub. 15-A.
Please type or print.
Name (as distinguished from trade name)
Calendar year
Trade name, if any
Employer identification number (EIN)
Address (number and street)
City, state, and ZIP code
If address is
different
from prior
return, check
here. A
If you do not have to file returns in the future, check here
and enter date final payments made.
1
Federal income tax withheld from pensions, annuities, IRAs, gambling winnings, etc.
1
2
Backup withholding
2
3
Adjustment to correct administrative errors (see the instructions)
3
4
Total taxes. If $2,500 or more, this must equal line 8M below or line M of Form 945-A
4
5
Total deposits for 2008 from your records, including overpayment applied from 2007 return
5
6
Balance due (subtract line 5 from line 4) (see the instructions)
6
7
Overpayment. If line 4 is less than line 5, enter overpayment here
$
Applied to next return or
2008
and check if to be:
Refunded.
● All filers: If line 4 is less than $2,500, do not complete line 8 or Form 945-A.
● Semiweekly schedule depositors: Complete Form 945-A and check here
● Monthly schedule depositors: Complete line 8, entries A through M, and check here
8
Monthly Summary of Federal Tax Liability. (Do not complete if you were a semiweekly schedule depositor.)
Tax liability for month
Tax liability for month
Tax liability for month
A January
F June
B February
G July
L December
C March
D April
E May
H August
I September
J October
M Total liability for
year (add lines A
through L)
ThirdParty
Designee
Sign
Here
K November
Do you want to allow another person to discuss this return with the IRS (see the instructions)?
Designee’s
name Phone
no.
(
)
Yes. Complete the following.
No.
Personal identification
number (PIN)
Under penalties of perjury, I declare that I have examined this return, including accompanying schedules and statements, and to the best of my knowledge
and belief, it is true, correct, and complete. Declaration of preparer (other than taxpayer) is based on all information of which preparer has any knowledge.
Signature
Paid
Preparer’s
Use Only
Print Your
Name and Title
Date
Preparer’s
signature
Firm’s name (or
yours, if self-employed),
address, and ZIP code
For Privacy Act and Paperwork Reduction Act Notice, see the separate instructions.
Clearstream Banking
Customer Tax Guide - United States of America
Date Preparer’s SSN or PTIN
Check
if selfemployed
EIN
Phone no. (
Cat. No. 14584B
)
Form
945
(2008)
March 2013
A - 59
United States of America - Appendices
Appendix 21 (cont). IRS Form 945 (Annual Return of Withheld Federal Income Tax)
Form 945-V,
Payment Voucher
Complete Form 945-V, Payment Voucher, if you are
making a payment with Form 945, Annual Return of
Withheld Federal Income Tax. We will use the
completed voucher to credit your payment more
promptly and accurately, and to improve our service to
you.
If you have your return prepared by a third party and
make a payment with that return, please provide Form
945-V to the return preparer.
Making Payments With Form 945
To avoid a penalty, make your payment with your 2008
Form 945 only if:
● Your total taxes for the year (line 4 on Form 945) are
less than $2,500 and you are paying in full with a
timely filed return or
● You are a monthly schedule depositor making a
payment in accordance with the Accuracy of Deposits
Rule. See section 11 of Pub. 15 (Circular E),
Employer’s Tax Guide, for details. In this case, the
amount of your payment may be $2,500 or more.
Otherwise, you must deposit your payment at an
authorized financial institution or by using the
Electronic Federal Tax Payment System (EFTPS). See
section 11 of Pub. 15 (Circular E) for deposit
instructions. Do not use Form 945-V to make federal
tax deposits.
✁
Specific Instructions
Box 1—Employer identification number (EIN). If you
do not have an EIN, apply for one on Form SS-4,
Application for Employer Identification Number, and
write “Applied For” and the date you applied in this
entry space.
Box 2—Amount paid. Enter the amount paid with
Form 945.
Box 3—Name and address. Enter your name and
address as shown on Form 945.
● Enclose your check or money order made payable to
the “United States Treasury.” Be sure to enter your
EIN, “Form 945,” and “2008” on your check or money
order. Do not send cash. Do not staple Form 945-V or
your payment to the return (or to each other).
● Detach Form 945-V and send it with your payment
and Form 945 to the address provided in the
Instructions for Form 945.
Note. You must also complete the entity information
above line A on Form 945.
Detach Here and Mail With Your Payment and Form 945. Payment Voucher
Form 945-V
Department of the Treasury
Internal Revenue Service
1
Caution. Use Form 945-V when making any payment
with Form 945. However, if you pay an amount with
Form 945 that should have been deposited, you may
be subject to a penalty. See Deposit Penalties in
section 11 of Pub. 15 (Circular E).
Enter your employer identification number (EIN).
2
3
✃
Purpose of Form
OMB No. 1545-1430
2008
Do not attach this voucher or your payment to Form 945.
Enter the amount of your payment
Dollars
Cents
Enter your business name (individual name if sole proprietor).
Enter your address.
Enter your city, state, and ZIP code.
March 2013
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Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 22. IRS Form 1042 (Annual Withholding Tax Return for U.S.
Source Income of Foreign Persons) - 2008
Form
1042
Annual Withholding Tax Return for
U.S. Source Income of Foreign Persons
Department of the Treasury
Internal Revenue Service (77)
OMB No. 1545-0096
2008
See instructions.
If this is an amended return, check here
Name of withholding agent
For IRS Use Only
Employer identification number
CC
RD
CAF
CR
EDC
Number, street, and room or suite no. (if a P.O. box, see instructions)
City or town, province or state, and country (including postal code)
FD
FF
FP
I
SIC
If you will not be liable for returns in the future, check here Enter date final income paid Check here if you made quarter-monthly deposits using the 90% rule (see Deposit Requirements in the instructions)
Check if you are a:
QI/Withholding foreign partnership or trust
NQI/Flow-through entity
(See instructions.)
Record of Federal Tax Liability (Do not show federal tax deposits here.)
Line
No.
Period
ending
Tax liability for period
(including any taxes assumed Line
No.
on Form(s) 1000)
Period
ending
Tax liability for period
(including any taxes assumed Line
No.
on Form(s) 1000)
1
7
21
7
2
15
22
15
Jan.
May
3
22
23
22
4
31
24
31
25 May total
5 Jan. total
6
7
26
7
7
15
27
15
June
Feb. 22
8
28
22
9
29
29
30
10 Feb. total
30 June total
11
7
31
7
12
15
32
15
July
Mar.
13
22
33
22
14
31
34
31
15 Mar. total
35 July total
16
7
36
7
17
15
37
15
Apr.
Aug.
18
22
38
22
19
30
39
31
20 Apr. total
40 Aug. total
61 No. of Forms 1042-S filed: a On paper
62 For all Form(s) 1042-S and 1000: a Gross income paid
63a
b
c
64
65
66
67
68
69
70
71
Period
ending
41
7
42
15
Sept.
43
22
44
30
45 Sept. total
46
7
47
15
Oct.
48
22
49
31
50 Oct. total
51
7
52
15
Nov.
53
22
54
30
55 Nov. total
56
7
57
15
Dec.
58
22
59
31
60 Dec. total
b Electronically
b Taxes withheld or assumed
63a
Total tax liability (add monthly total lines from above)
63b
Adjustments (see page 4)
Total net tax liability (combine lines 63a and 63b)
Total paid by federal tax deposit coupons or by electronic funds
64
transfer (or with a request for an extension of time to file) for 2008
65
Enter overpayment applied as a credit from 2007 Form 1042
66
Credit for amounts withheld by other withholding agents (see page 4)
Total payments. Add lines 64 through 66
If line 63c is larger than line 67, enter balance due here
If line 67 is larger than line 63c, enter overpayment here
Penalty for failure to deposit tax when due. Also include on line 68 or line 69 (see page 4)
Apply overpayment on line 69 to (check one):
Credit on 2009 Form 1042 or
Refund
Third Party
Designee
Sign
Here
Paid
Preparer’s
Use Only
Tax liability for period
(including any taxes assumed
on Form(s) 1000)
Do you want to allow another person to discuss this return with the IRS (see page 4)?
63c
67
68
69
70
Yes. Complete the following.
No
Designee’s
Phone
Personal identification
name
no.
number (PIN)
Under penalties of perjury, I declare that I have examined this return, including accompanying schedules and statements, and to the best of my knowledge and
belief, it is true, correct, and complete. Declaration of preparer (other than withholding agent) is based on all information of which preparer has any knowledge.
Capacity in which acting Date
Your
Daytime phone number signature
Preparer’s
signature
Firm’s name (or
yours if self-employed),
address, and ZIP code
Date
Check if
self-employed
Preparer’s SSN or PTIN
For Privacy Act and Paperwork Reduction Act Notice, see the instructions.
Clearstream Banking
Customer Tax Guide - United States of America
EIN
Phone no.
Cat. No. 11384V
Form
1042
(2008)
March 2013
A - 61
United States of America - Appendices
Appendix 22 (cont). IRS Form 1042 (2008) (Annual Withholding Tax Return for U.S.
Source Income of Foreign Persons)
Form 1042 (2008)
Section references are to the Internal
Revenue Code unless otherwise noted.
General Instructions
Purpose of Form
Use Form 1042 to report tax withheld on
certain income of foreign persons,
including nonresident aliens, foreign
partnerships, foreign corporations, foreign
estates, and foreign trusts.
Publicly traded partnerships (section
1446 withholding tax). For purposes of
reporting on Form 1042, a publicly traded
partnership (PTP) must withhold section
1446 tax on distributions of effectively
connected income (ECI) to its foreign
partners. A nominee that receives a
distribution of ECI from a PTP and is
treated as the withholding agent must use
Form 1042 to report the tax withheld. For
this purpose, a nominee is a domestic
person holding an interest in the PTP on
behalf of one or more foreign partners. For
more information, see Regulations section
1.1446-4 and Pub. 515, Withholding of Tax
on Nonresident Aliens and Foreign Entities.
Who Must File
Every withholding agent or intermediary
(see definitions below) who receives,
controls, has custody of, disposes of, or
pays any fixed or determinable annual or
periodical income must file an annual
return for the preceding calendar year on
Form 1042. Also, any PTP or nominee
making a distribution of ECI under section
1446 must file Form 1042 for the preceding
calendar year.
You must file Form 1042 if either of the
following apply.
● You are required to file Form(s) 1042-S
(whether or not any tax was withheld or
was required to be withheld). File Form
1042 even if you file Forms 1042-S
electronically.
● You pay gross investment income to
foreign private foundations that are subject
to tax under section 4948(a).
Withholding Agent
Any person required to withhold tax is a
withholding agent. A withholding agent
may be an individual, trust, estate,
partnership, corporation, nominee (under
section 1446), government agency,
association, or tax-exempt foundation,
whether domestic or foreign.
CAUTION
Every person required to deduct
and withhold any tax under
Chapter 3 of the Code is liable
for such tax. See section 1461.
Intermediary
An intermediary is 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.
Qualified intermediary (QI). A QI is an
intermediary that is a party to a withholding
agreement with the IRS. An entity must
March 2013
A - 62
Page
indicate its status as a QI on a Form
W-8IMY submitted to a withholding agent.
For information on a QI withholding
agreement, see Rev. Proc. 2000-12, which
is on page 387 of Internal Revenue Bulletin
(IRB) 2000-4 at
www.irs.gov/pub/irs-irbs/irb00-04.pdf. Also
see Notice 2001-4 (IRB 2001-2), as
amended; Rev. Proc. 2003-64, Appendix 3
(IRB 2003-32); Rev. Proc. 2004-21 (IRB
2004-14); and Rev. Proc. 2005-77 (IRB
2005-51).
Withholding foreign partnership (WP) or
withholding foreign trust (WT). A WP or
WT is a foreign partnership or trust that
has entered into a withholding 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
information on these withholding
agreements, see Rev. Proc. 2003-64,
which is on page 306 of Internal Revenue
Bulletin (IRB) 2003-32 at
www.irs.gov/pub/irs-irbs/irb03-32.pdf. Also
see Rev. Proc. 2004-21 (IRB 2004-14) and
Rev. Proc. 2005-77 (IRB 2005-51).
Nonqualified intermediary (NQI). An NQI
is any intermediary that is not a U.S.
person and that is not a QI.
Where and When To File
File Form 1042 with the Ogden Service
Center, P.O. Box 409101, Ogden, UT
84409, by March 16, 2009. Use Form
1042-T to transmit paper Forms 1042-S.
Extension of time to file. If you need
more time to file Form 1042, you may
submit Form 7004, Application for
Automatic Extension of Time To File
Certain Business Income Tax, Information,
and Other Returns.
Form 7004 does not extend the time for
payment of tax.
Additional Information
For details on withholding of tax, see Pub.
515. You can get Pub. 515 by calling
1-800-TAX-FORM (1-800-829-3676) or by
downloading it from the IRS website at
www.irs.gov.
Income Tax Withholding on
Wages, Pensions, Annuities,
and Certain Other Deferred
Income
Use Form 941, Employer’s QUARTERLY
Federal Tax Return, to report income tax
withheld and social security and Medicare
taxes on wages paid to a nonresident alien
employee.
Use Form 945, Annual Return of
Withheld Federal Income Tax, to report
income tax withheld under section 3405
from pensions, annuities, and certain other
deferred income paid to a nonresident
alien individual. However, if the recipient
has elected under section 3405(a)(2) or
(b)(2) not to have withholding under section
3405, these payments are subject to
withholding under section 1441 and the tax
withheld must be reported using Forms
1042 and 1042-S.
2
Use Schedule H (Form 1040), Household
Employment Taxes, to report income tax
withheld and social security and Medicare
taxes on wages paid to a nonresident alien
household employee.
Deposit Requirements
Generally, if you are not required to use
the Electronic Federal Tax Payment
System (EFTPS), you must deposit the tax
withheld and required to be shown on
Form 1042 with an authorized financial
institution using your preprinted Form
8109, Federal Tax Deposit Coupon. Do not
use anyone else’s coupons. If you do not
have your coupons when a deposit is due,
call 1-800-829-4933, if you are in the
United States. If overseas, call
215-516-2000 (not a toll-free number). You
may also contact your local IRS office. To
avoid a penalty, do not mail your deposits
directly to the IRS.
The amount of tax you are required to
withhold determines the frequency of your
deposits. The following rules explain how
often deposits must be made.
1. If at the end of any quarter-monthly
period the total amount of undeposited
taxes is $2,000 or more, you must deposit
the taxes within 3 banking days after the
end of the quarter-monthly period. (A
quarter-monthly period ends on the 7th,
15th, 22nd, and last day of the month.) To
determine banking days, do not count
Saturdays, Sundays, legal holidays, or any
local holidays observed by authorized
financial institutions.
This deposit rule is considered met if:
● You deposit at least 90% of the actual
tax liability for the deposit period, and
● If the quarter-monthly period is in a
month other than December, you deposit
any underpayment with your first deposit
that is required to be made after the 15th
day of the following month. Any
underpayment of $200 or more for a
quarter-monthly period ending in
December must be deposited by
January 31.
2. If at the end of any month the total
amount of undeposited taxes is at least
$200 but less than $2,000, you must
deposit the taxes within 15 days after the
end of the month. If you make a deposit of
$2,000 or more during any month except
December under rule 1 above, carry over
any end-of-the-month balance of less than
$2,000 to the next month. If you make a
deposit of $2,000 or more during
December, any end-of-December balance
of less than $2,000 should be remitted with
your Form 1042 by March 16, 2009.
3. If at the end of a calendar year the
total amount of undeposited taxes is less
than $200, you may either pay the taxes
with your Form 1042 or deposit the entire
amount by March 16, 2009.
Note. If you are requesting an extension of
time to file using Form 7004, follow these
rules to see if you must make a deposit of
any balance due or if you can pay it with
Form 7004. See Form 7004 and its
instructions for more information.
Clearstream Banking
Customer Tax Guide - United States of America
United States of America - Appendices
Appendix 22 (cont). IRS Form 1042 (20081) (Annual Withholding Tax Return for U.S.
Source Income of Foreign Persons)
Form 1042 (2008)
Electronic deposit requirement. You
must make electronic deposits of all
depository tax liabilities using the
Electronic Federal Tax Payment System
(EFTPS) in 2009 if:
● The total deposits of such taxes in 2007
were more than $200,000, or
● You were required to use EFTPS in
2008.
If you are required to use EFTPS and fail
to do so, you may be subject to a 10%
penalty. If you are not required to use
EFTPS, you may participate voluntarily. To
enroll in or get more information about
EFTPS, call 1-800-555-4477. You can also
visit the EFTPS website at www.eftps.gov.
Depositing on time. For deposits made
by EFTPS to be on time, you must initiate
the transaction at least one business day
before the date the deposit is due.
Completing Form 8109. If you do not use
EFTPS, deposit your income tax payments
using Form 8109. In most cases, you will
fill out a Form 8109 following the
instructions in the coupon book. However,
if a deposit liability arises from a
distribution reportable on Form 1042 for
the prior year, darken the 4th quarter
space on Form 8109. If the distribution is
reportable for the current year, darken the
1st quarter space. In all cases, follow the
coupon book instructions for completing
the rest of the deposit coupon. To ensure
proper crediting, write your taxpayer
identification number, the period to which
the tax deposit applies, and “Form 1042”
on the check or money order.
If you prefer you may mail your coupon
and payment to:
Financial Agent
Federal Tax Deposit Processing
P.O. Box 970030
St. Louis, MO 63197 U.S.A.
Make your check or money order
payable to “Financial Agent.”
Interest and Penalties
If you file Form 1042 late, or fail to pay or
deposit the tax when due, you may be
liable for penalties and interest unless you
can show that the failure to file or pay was
due to reasonable cause and not willful
neglect.
You do not have to figure the
amount of any interest or
penalties you may owe. Because
figuring these amounts can be
complicated, we will do it for you if you
want. We will send you a bill for any
amount due.
TIP
If you include interest or penalties (other
than the penalty for failure to deposit tax
when due) with your payment, identify and
enter the amount in the bottom margin of
Form 1042, page 1. Do not include interest
or penalties (other than the penalty for
failure to deposit tax when due) in the
balance due on line 68.
Interest. Interest is charged on taxes not
paid by the due date, even if an extension
of time to file is granted. Interest is also
charged on penalties imposed for failure to
Page
file, negligence, fraud, and substantial
understatements of tax from the due date
(including extensions) to the date of
payment. Interest is figured at a rate
determined under section 6621.
Late filing of Form 1042. The penalty for
not filing Form 1042 when due (including
extensions) is 5% of the unpaid tax for
each month or part of a month the return
is late, up to a maximum of 25% of the
unpaid tax.
Late payment of tax. The penalty for not
paying tax when due is usually 1⁄2 of 1%
of the unpaid tax for each month or part of
a month the tax is unpaid. The penalty
cannot exceed 25% of the unpaid tax.
Failure to deposit tax when due. See the
instructions for line 70 on page 4.
Other penalties. Penalties may be
imposed for negligence, substantial
understatement of tax, and fraud. See
sections 6662 and 6663.
Specific Instructions
File only one Form 1042
consolidating all Form 1042-S
recipient information, regardless
CAUTION of the number of different
clients, branches, divisions, or types of
income for which you are the withholding
agent. However, if you are acting in more
than one capacity (for example, you are
acting as a QI for certain designated
accounts and as an NQI for other
accounts), file a separate Form 1042 for
each capacity in which you are acting.
Rounding off to whole dollars. You may
round off cents to whole dollars. If you do
round to whole dollars, you must round all
amounts. To round off amounts to the
nearest whole dollar, drop amounts under
50 cents and increase amounts from 50 to
99 cents to the next dollar. For example,
$1.39 becomes $1 and $2.50 becomes
$3. If you have to add two or more
amounts to figure the amount to enter on
a line, include cents when adding and
only round off the total.
Employer identification number (EIN).
You are generally required to enter your
EIN. However, if you are filing Form 1042 as
a QI, withholding foreign partnership, or
withholding foreign trust, enter your QI-EIN,
WP-EIN, or WT-EIN. Also, be sure to check
the “QI/Withholding foreign partnership or
trust” box. See QI and NQI checkboxes
below.
If you do not have an EIN, you can
apply for one online at
www.irs.gov/businesses or by telephone at
1-800-829-4933. Also, you can file Form
SS-4, Application for Employer
Identification Number, by fax or mail. File
amended Forms 1042-S when you receive
your EIN.
To get a QI-EIN, WP-EIN, or WT-EIN,
submit Form SS-4 with your application for
that status. Do not send an application for
a QI-EIN, WP-EIN, or WT-EIN to the
addresses listed in the Instructions for
Form SS-4.
Clearstream Banking
Customer Tax Guide - United States of America
3
Address. Include the suite, room, or other
unit number after the street address. If
your post office does not deliver mail to
the street address and you have a P.O.
box, show the box number instead of the
street address.
QI and NQI checkboxes. See page 2 for
definitions of intermediary, qualified
intermediary (QI), withholding foreign
partnership (WP), withholding foreign trust
(WT), and nonqualified intermediary (NQI).
See the Form 1042-S instructions for
definitions of U.S. branch treated as a U.S.
person and flow-through entity.
Check the “QI/Withholding foreign
partnership or trust” box on page 1 if you
are a QI, WP, WT, or a U.S. branch treated
as a U.S. person. Check the
“NQI/Flow-through entity” box if you are an
NQI or a flow-through entity.
Lines 1 through 60. Except as otherwise
provided in these instructions, include tax
liability for the period in which the income
was distributed. Do not enter any negative
amounts on these lines.
A domestic partnership that has not
distributed a foreign partner’s distributive
share of income subject to withholding
under section 1441 must withhold tax on
any income not distributed by the date on
which the Schedule K-1 is sent or
otherwise furnished to the foreign partner
(or, if earlier, the due date for furnishing
Schedule K-1 to the partner). Include such
tax for the period that includes the date
the tax was required to be withheld.
Do not include on lines 1 through 60 any
tax liability attributable to adjustments of
underwithheld tax on corporate
distributions made in calendar year 2008 if:
● The distributing corporation made a
reasonable estimate of accumulated and
current earnings and profits under
Regulations section 1.1441-3(c)(2)(ii)(A) and
● The distributing corporation or
intermediary paid over the underwithheld
tax by March 16, 2009.
Instead, include these payments of
underwithheld tax on line 63b.
If you are a QI that did not assume
primary withholding responsibility, enter the
total amount withheld by the U.S.
withholding agent(s) on line 59. Report all
other amounts (that is, amounts you
actually withheld) on the line that
corresponds with the date the liability was
incurred.
If you repaid the recipient for an amount
overwithheld by reducing the amount
withheld on a later payment, report the
reduced amount on these lines. If you used
the reimbursement procedure for
overwithheld amounts, see Pub. 515.
Line 61. Enter the number of Forms
1042-S filed on paper and electronically.
Lines 62a and 62b. Enter the amounts
requested with respect to all Forms 1042-S
(regardless of whether the form was filed
electronically or on paper) and with respect
to all Forms 1000, Ownership Certificate.
March 2013
A - 63
United States of America - Appendices
Appendix 22 (cont). IRS Form 1042 (20081) (Annual Withholding Tax Return for U.S.
Source Income of Foreign Persons)
Form 1042 (2008)
Page
Be sure to reconcile amounts on
Form 1042 with amounts on
Forms 1042-S (including Forms
CAUTION 1042-S filed electronically), to
avoid unnecessary correspondence with
the IRS.
Line 62a. The amount on line 62a should
equal the sum of all amounts shown on
Forms 1042-S, box 2, and all amounts
shown as gross interest paid on Forms
1000.
Line 62b. The amount on line 62b
should equal:
● The sum of all Forms 1042-S, box 9 (box
7 plus box 8), less
● The sum of all Forms 1042-S, box 10,
plus
● The tax assumed from Forms 1000.
If it does not, attach a statement to Form
1042 explaining the difference.
Line 63a. The amount on line 63a must
equal the sum of the monthly totals as
listed on the Record of Federal Tax
Liability. Do not make any adjustments on
this line. Except for adjustments described
in the instructions for line 63b, you may
only make adjustments on the appropriate
entry line of the Record of Federal Tax
Liability.
claimed on line 66. Failure to do so will
result in the denial of the refund or credit
being claimed. If you are a PTP or a
nominee withholding under section 1446,
the tax paid for a payee may only be
claimed as a credit by the payee.
Lines 69 and 71. You may claim an
overpayment shown on line 69 as a refund
or a credit. Check the applicable box on
line 71 to show which you are claiming. If
you claim a credit, it can reduce your
required deposits of withheld tax for 2009.
Line 63b. Include on line 63b any tax
liability attributable to adjustments of
underwithheld tax on corporate
distributions made in calendar year 2008 if:
● The distributing corporation made a
reasonable estimate of accumulated and
current earnings and profits under
Regulations section 1.1441-3(c)(2)(ii)(A) and
● The distributing corporation or
intermediary paid over the underwithheld
tax by March 16, 2009.
If you are a regulated investment
company (RIC) or a real estate investment
trust (REIT) that paid a dividend in January
subject to section 852(b)(7) or section
857(b)(9) (relating to certain dividends
declared in the preceding October,
November, or December), enter your
additional tax liability on those dividends
declared in 2008 but paid in January 2009
less any additional tax liability on those
dividends declared in 2007 but paid in
January 2008. Show any negative amount
in brackets. Attach a statement showing
your calculation.
If you want to allow any individual,
corporation, firm, organization, or
partnership to discuss your 2008 Form
1042 with the IRS, check the “Yes” box in
the Third Party Designee section of the
return. Also, enter the name, phone
number, and any five numbers that the
designee chooses as his or her personal
identification number (PIN). The
authorization applies only to the tax form
upon which it appears.
By checking the “Yes” box, you are
authorizing the IRS to call the designee to
answer any questions relating to the
information reported on your tax return.
You are also authorizing the designee to:
● Exchange information concerning your
tax return with the IRS, and
● Request and receive written tax return
information relating to your tax return
including copies of specific notices,
correspondence, and account transcripts.
You are not authorizing the designee to
receive any refund check, bind you to
anything (including additional tax liability),
or otherwise represent you before the IRS.
If you want to expand the designee’s
authorization, see Pub. 947, Practice
Before the IRS and Power of Attorney.
The authorization automatically expires
one year from the due date (without regard
to extensions) for filing your 2008 Form
1042. If you or your designee desire to
terminate the authorization, a written
statement conveying your wish to revoke
the authorization should be submitted to
the IRS service center where the return
was processed.
Line 64. Enter the total tax deposits you
made (including amounts paid with an
extension of time to file).
Line 66. You are permitted to take a
credit for amounts withheld by other
withholding agents that pertain to the
total net tax liability reported on line 63c.
For example, you are a QI and the
amount you entered on line 63c includes
amounts withheld by a U.S. withholding
agent. You may take a credit on line 66
for the amounts that were withheld by
the U.S. withholding agent. The amount
on line 66 should equal the sum of all
Forms 1042-S, box 8, that you file for
the year.
CAUTION
March 2013
A - 64
If you are a QI requesting a
refund, you must attach the
corresponding Form(s) 1042-S
received to support the amount
Line 70. The penalty for failure to deposit
tax applies to the amount underpaid when
the deposit was due. See Deposit
Requirements on page 2. The penalty rates
are 2% for deposits made 1 to 5 days late,
5% for deposits made 6 to 15 days late,
and 10% for deposits made 16 or more
days late. However, the penalty is 15% if
the tax is not deposited within 10 days after
the IRS issues the first notice demanding
payment. Add the penalty to any tax due
and enter the total on line 68. If you are due
a refund, subtract the penalty from the
overpayment you show on line 69.
For information on other penalties, see
Interest and Penalties on page 3.
Third Party Designee
Amended Return
If you have to make changes to your Form
1042 after you submit it, file an amended
Form 1042. Use a Form 1042 for the year
you are amending. Check the “Amended
Return” box at the top of the form. You
4
must complete the entire form, including all
filing information for the calendar year, and
sign the return. Attach a statement
explaining why you are filing an amended
return (for example, you are filing because
the tax liability for May was incorrectly
reported due to a mathematical error).
If you are also amending Form(s)
1042-S, see Amended Returns in the Form
1042-S instructions.
Do not amend Form 1042 to recover
taxes overwithheld in the prior year. For
more information, see Adjustment for
Overwithholding in Pub. 515.
Privacy Act and Paperwork Reduction
Act Notice. We ask for the information on
this form to carry out the Internal Revenue
laws of the United States. Sections 1441,
1442, and 1446 (for PTPs) require
withholding agents to report and pay over
to the IRS taxes withheld from certain U.S.
source income of foreign persons. Form
1042 is used to report the amount of
withholding that must be paid over. Form
1042-S is used to report the amount of
income and withholding to the payee.
Section 6109 requires you to provide your
employer identification number. Routine
uses of this information include giving it to
the Department of Justice for civil and
criminal litigation, and cities, states, and
the District of Columbia for use in
administering their tax laws. We may also
disclose this information to other countries
under a tax treaty, to federal and state
agencies to enforce federal nontax criminal
laws, or to federal law enforcement and
intelligence agencies to combat terrorism.
If you fail to provide this information in a
timely manner, you may be liable for
penalties and interest.
You are not required to provide the
information requested on a form that is
subject to the Paperwork Reduction Act
unless the form displays a valid OMB
control number. Books or records relating
to a form or its instructions must be
retained as long as their contents may
become material in the administration of
any Internal Revenue law. Generally, tax
returns and return information are
confidential, as required by section 6103.
The time needed to complete and file
these forms will vary depending on
individual circumstances. The estimated
average time is: Recordkeeping, 9 hr., 48
min.; Learning about the law or the form,
2 hr., 25 min.; Preparing the form, 4 hr.,
33 min.; and Copying, assembling, and
sending the form to the IRS, 32 min.
If you have comments concerning the
accuracy of these time estimates or
suggestions for making this form simpler,
we would be happy to hear from you. You
can write to the Internal Revenue Service,
Tax Products Coordinating Committee,
SE:W:CAR:MP:T:T:SP, 1111 Constitution
Ave. NW, IR-6526, Washington, DC 20224.
Do not send the form to this address.
Instead, see Where and When To File on
page 2.
Clearstream Banking
Customer Tax Guide - United States of America