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フォームW-8IMYの手順, 外国の仲介の証明書, 外国のフロー・スラフ・エンティティ, または米国のための特定の米国支店 米国の税額の保有と報告

2021年10月改訂

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  • フォーム W-8IMY - 外国の仲介業者、外国のフロー・スルーエンティティティ、または米国税保持および報告のための特定の米国支店の証明書
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Department of the Treasury  
Internal Revenue Service  
Instructions for Form W-8IMY  
(Rev. October 2021)  
Certificate of Foreign Intermediary, Foreign Flow-Through Entity, or Certain U.S.  
Branches for United States Tax Withholding and Reporting  
Section references are to the Internal Revenue Code unless  
otherwise noted.  
2022. As a result, this Form W-8IMY includes chapter 3  
status certifications for entities acting as QSLs (applicable to  
either a qualified intermediary (QI) or other entity acting as a  
QSL) and clarifies (as provided in the QI agreement) when a  
QI may continue to claim status as a QSL in a case in which it  
is also a qualified derivatives dealer (QDD).  
General Instructions  
Future developments. For the latest information about  
developments related to Form W-8IMY and its instructions,  
such as legislation enacted after they were published, go to  
New lines 9a and 9b. Line 9b, foreign taxpayer  
identification number, if required, has been added for a QDD  
to indicate its foreign taxpayer identification number (FTIN)  
on this form (with line 9, GIIN (if applicable), redesignated as  
line 9a). See QDD withholding statement, later, for when a  
QDD is required to provide its FTIN on line 9b.  
What’s New  
Guidance under section 1446(f). The Tax Cuts and Jobs  
Act (TCJA), added section 1446(f), which generally requires  
that if any portion of a gain on any disposition of an interest in  
a partnership would be treated under section 864(c)(8) as  
effectively connected gain, the transferee purchasing an  
interest in such a partnership from a non-U.S. transferor must  
withhold a tax equal to 10% of the amount realized on the  
disposition unless an exception to withholding applies. T.D.  
9926 (84 FR 76910), published on November 30, 2020,  
contains final regulations (section 1446(f) regulations)  
relating to the withholding and reporting required under  
section 1446(f), which include withholding requirements that  
apply to brokers effecting transfers of interests in publicly  
traded partnerships (PTPs). The section 1446(f) regulations  
also revise certain requirements under section 1446(a)  
relating to withholding and reporting on distributions made by  
PTPs, including by expanding the entities permitted to act as  
nominees for PTP distributions to include certain qualified  
intermediaries and U.S. branches of foreign persons that  
agree to act as U.S. persons. Withholding on transfers of  
interests in PTPs and the revisions included in the section  
1446(f) regulations relating to withholding on PTP  
Nonqualified intermediary (NQI) that provides an alter-  
native withholding statement. The Form W-8IMY and  
these instructions have been updated to allow an NQI that is  
to provide alternative withholding statements and beneficial  
owner withholding certificates for payments associated with  
this form to represent on the form that the information on the  
withholding certificates will be verified for consistency with  
any other account information the NQI has for the beneficial  
owners for determining the rate of withholding with respect to  
each payee (applying the standards of knowledge under  
section 1441 or 1471 regulations, as applicable). See T.D.  
9890 and Regulations section 1.1441-1(e)(3)(iv)(C)(3). When  
applicable, an NQI may make this representation on new  
line 17e instead of on its withholding statement. The Form  
W-8IMY and these instructions have also been updated to  
allow nonwithholding foreign partnerships and  
nonwithholding foreign trusts to make this representation  
when providing an alternative withholding statement. For  
further information, see the instructions for line 21f.  
Electronic signature. These instructions have been  
updated to include additional guidance included in final  
regulations issued under chapter 3 (T.D. 9890) concerning  
the use of electronic signatures on withholding certificates.  
See Part XXIX Certification, later, and Regulations section  
1.1441-1(e)(4)(i)(B).  
Section 6050Y reporting. These instructions have been  
updated to reference the use of this form by a foreign  
partnership, foreign simple trust, or foreign grantor trust that  
is the seller of a life insurance contract (or interest therein) or  
a recipient of a reportable death benefit for purposes of  
reporting under section 6050Y.  
distributions under section 1446(a) apply to transfers and  
distributions that occur on or after January 1, 2023. See  
Notice 2021-51, 2021-36 I.R.B. 361, for more information.  
The provisions of the section 1446(f) regulations relating to  
withholding and reporting on transfers of interests in  
partnerships that are not PTPs generally apply to transfers  
occurring after January 29, 2021. See Pub. 515 for an  
additional discussion of section 1446(f) withholding. The  
Form W-8IMY and these instructions have been updated to  
incorporate the use of this form by brokers and certain  
transferors of partnership interests for purposes of certain of  
the requirements of the section 1446(f) regulations for  
withholding on dispositions of partnership interests (in both  
PTPs and other partnerships) and for withholding on PTP  
distributions.  
Purpose of Form  
Under chapter 3, foreign persons are generally subject to  
U.S. tax at a 30% rate on income they receive from U.S.  
sources that consists of interest (including certain original  
issue discount (OID)), dividends, rents, premiums, annuities,  
compensation for, or in expectation of, services performed,  
or other fixed or determinable annual or periodical (FDAP)  
gains, profits, or income. This tax is imposed on the gross  
amount paid and is generally collected by withholding under  
section 1441 or 1442 on that amount. A payment is  
Section 871(m) regulations and qualified securities  
lenders (QSLs). Notice 2020-2, 2020-3 I.R.B. 327, further  
extended the transition relief provided in Notice 2018-72,  
2018-40 I.R.B. 522, for certain provisions of the section  
871(m) regulations, generally for 2021 and 2022. Notice  
2020-2 also further extended the period that a withholding  
agent may apply the transition rules to act as a QSL  
considered to have been made whether it is made directly to  
the beneficial owner or to another person, such as an  
described in obsoleted Notice 2010-46, 2010-24 I.R.B. 757,  
Part III, for substitute dividend payments made in 2021 and  
Nov 02, 2021  
Cat. No. 25904R  
intermediary, agent, trustee, executor, or partnership, for the  
benefit of the beneficial owner.  
Additional information. For additional information and  
instructions for the withholding agent, see the Instructions for  
the Requester of Forms W-8BEN, W-8BEN-E, W-8ECI,  
W-8EXP, and W-8IMY.  
Under chapter 4, withholding agents must withhold at a  
30% rate under sections 1471 and 1472 on withholdable  
payments made to nonparticipating foreign financial  
institutions (FFIs) (including when the nonparticipating FFI is  
a flow-through entity or is acting as an intermediary), certain  
other foreign entities, and certain account holders of FFIs.  
For example, if a U.S. withholding agent makes a payment of  
portfolio interest described in section 871(h) to an account  
maintained by a nonparticipating FFI, the payment will be  
subject to a 30% withholding tax under section 1471 even if  
the nonparticipating FFI is an intermediary or flow-through  
entity and the beneficial owner for whom the intermediary or  
flow-through is acting is a foreign individual who provides a  
valid Form W-8BEN.  
Who Must Provide Form W-8IMY  
Except as otherwise provided, you should provide Form  
W-8IMY when receiving a reportable amount or withholdable  
payment on behalf of another person or as a flow-through  
entity or when acting as a QDD or QSL. When receiving a  
withholdable payment, your chapter 4 status is generally  
required to be included on the form unless otherwise  
provided in accordance with these instructions. In some  
cases you should provide Form W-8IMY for an amount  
realized or a PTP distribution. Form W-8IMY must be  
provided by the following persons.  
A foreign person, or a foreign branch of a U.S. person, to  
establish that it is a QI that is not acting for its own account,  
to represent that it has provided or will provide a withholding  
statement, as required, or, if applicable, to represent that it  
has assumed primary withholding responsibility under  
chapters 3 and 4 and/or primary Form 1099 reporting and  
backup withholding responsibility.  
Foreign persons are also subject to tax at graduated rates  
on income they earn that is considered effectively connected  
with a U.S. trade or business. If a foreign person invests in a  
partnership that conducts a U.S. trade or business, the  
foreign person is considered to be engaged in a U.S. trade or  
business. The partnership is required to withhold tax under  
section 1446(a) on the foreign person’s distributive share of  
the partnership’s effectively connected taxable income or, in  
the case of a PTP, on the amount of a distribution attributable  
to effectively connected taxable income of the PTP as  
provided in Regulations section 1.1446-4 (excluding when a  
nominee rather than the PTP is required to withhold). For  
purposes of section 1446(a), the partnership may generally  
accept any beneficial owner withholding certificate submitted  
for purposes of section 1441 or 1442, with few exceptions, to  
establish the foreign status of the partner, including a  
withholding certificate that is associated with a Form W-8IMY  
submitted by an upper-tier foreign partnership, a foreign  
grantor trust, or a foreign intermediary. See Regulations  
sections 1.1446-1 through 1.1446-6 to determine whether a  
withholding certificate submitted for purposes of section  
1441 or 1442 will be accepted for purposes of section  
1446(a).  
A foreign person, a foreign branch of a foreign person, or a  
foreign branch of a U.S. person, to establish that it is a QI  
acting as a QDD, as permitted by the person’s QI agreement.  
A QDD that receives payments for which the QDD is entitled  
to a reduced rate of withholding under an income tax treaty  
may use its Form W-8IMY to both certify to its status as a QI  
acting as a QDD and to claim treaty benefits with respect to  
such payments. A QDD may also use its Form W-8IMY to  
claim an exemption from withholding that may apply based  
on the QDD’s status as a foreign beneficial owner of a  
payment.  
A foreign person, or a foreign branch of a U.S. person, to  
establish that it is a QI assuming primary withholding  
responsibility with respect to payments of substitute interest,  
as permitted by the QI agreement.  
For purposes of withholding under section 1446(f), a  
foreign person, or foreign branch of a U.S. person, to  
establish that it is a QI that is not acting for its own account  
and to represent that it has assumed primary withholding  
responsibility for a payment of an amount realized from the  
sale of an interest in a PTP or has provided, or will provide, a  
withholding statement, as required, for the amounts realized.  
Withholding may also be required under the section  
1446(f) regulations by a transferee paying the amount  
realized from a transfer of a partnership interest to a  
transferor of the interest or, for a transfer of an interest in a  
PTP, by a broker effecting the transfer. This withholding is  
generally required when any portion of the gain from the  
transfer would be treated as effectively connected gain under  
section 864(c)(8). The withholding required of a broker on an  
amount realized on the transfer of a PTP interest is subject to  
certain exceptions such as when an amount realized is paid  
to a qualified intermediary assuming withholding  
A foreign person, or a foreign branch of a U.S. person, to  
establish that it is a QI not acting for its own account, to  
represent that it has assumed primary withholding  
responsibility for distributions from PTPs for which the QI acts  
as a nominee or has provided, or will provide, a withholding  
statement, as required, for the distributions.  
A foreign person to establish that it is an NQI that is not  
acting for its own account for chapter 3 purposes (including  
for amounts subject to withholding under section 1446(a) or  
(f)), to certify its chapter 4 status (if required), to certify  
whether it reports U.S. accounts under chapter 4 (if required),  
and to indicate, if applicable, that it is using the form to  
transmit withholding certificates and/or other documentary  
evidence (when permitted) and has provided, or will provide,  
a withholding statement, when required (including for  
payments subject to withholding under section 1446(a) and,  
in certain cases, for section 1446(f)).  
responsibility under section 1446(f) or to a U.S. branch acting  
as a U.S. person for the amount realized. See Regulations  
section 1.1446(f)-4. For certain withholding exceptions, an  
applicable withholding certificate is required for a transfer of a  
PTP interest, such as for an entity to represent its status as  
an entity described in the preceding sentence (made on this  
Form W-8IMY) or for a transferor to claim an exemption from  
withholding based on an income tax treaty. A withholding  
certificate may also be required to establish the status of a  
broker or partner withheld upon under section 1446(f).  
Separate withholding exceptions apply to transfers of  
interests in partnerships other than PTPs, certain of which  
require the collection of a withholding certificate or other  
applicable certification. See Regulations section 1.1446(f)-2.  
A U.S. branch that is acting as an intermediary to  
represent that the income it receives is not effectively  
connected with the conduct of a trade or business within the  
United States and either that it is using the form (1) to  
-2-  
Instructions for Form W-8IMY (Rev. 10-2021)  
 
evidence it is treated as a U.S. person under Regulations  
section 1.1441-1(b)(2)(iv)(A) with respect to reportable  
amounts associated with the Form W-8IMY, or (2) to transmit  
the documentation of the persons for whom it receives a  
payment of such an amount and has provided, or will  
provide, a withholding statement, as required, and to certify it  
is applying the rules described in Regulations section  
1.1471-4(d)(2)(iii)(C) when receiving a withholdable  
payment.  
represent that it has provided, or will provide, a withholding  
statement with respect to a modified amount realized for  
purposes of withholding under section 1446(f) on the  
transfer.  
A foreign grantor trust transferring a partnership interest  
providing, on behalf of each grantor or other owner of the  
trust under Regulations section 1.1446(f)-1(c)(2)(vii), a  
withholding statement to allocate an amount realized to each  
grantor or owner for withholding under section 1446(f) on the  
transfer.  
For purposes of section 1446(f), a U.S. branch that is  
acting as an intermediary, to certify that it agrees to act as a  
U.S. person with respect to amounts realized on sales of  
interests in PTPs.  
A flow-through entity (including a foreign reverse hybrid  
entity) transmitting withholding certificates and/or other  
documentary evidence to claim treaty benefits on behalf of its  
owners, to certify its chapter 4 status (if required), and to  
certify that it has provided, or will provide, a withholding  
statement, as required.  
A U.S. branch, to represent that it is treated as a U.S.  
person and is acting as a nominee for distributions from  
PTPs under Regulations section 1.1446-4(b)(3) (or has  
otherwise provided (or will provide) a withholding statement  
for a distribution).  
A nonparticipating FFI acting as an intermediary or that is a  
flow-through entity using this form to transmit a withholding  
statement and withholding certificates or other  
documentation for exempt beneficial owners described in  
Regulations section 1.1471-6 with respect to its receipt of a  
withholdable payment.  
A financial institution incorporated or organized under the  
laws of a U.S. territory that is acting as an intermediary or is a  
flow-through entity to represent that it is a financial institution  
(other than an investment entity that is not also a depository  
institution, custodial institution, or specified insurance  
company) and either that it is using the form (1) to evidence it  
is treated as a U.S. person under Regulations section  
1.1441-1(b)(2)(iv)(A) with respect to payments of income that  
are not effectively connected with the conduct of a trade or  
business in the United States associated with the Form  
W-8IMY, or (2) to certify that it is transmitting documentation  
of the persons for whom it receives such payment and has  
provided, or will provide, a withholding statement, as  
required.  
A QSL that is either a QI (to the extent not acting as a  
QDD) or other entity certifying to a withholding agent that it is  
acting as a QSL in Part IV of Form W-8IMY with respect to  
U.S. source substitute dividends received from the  
withholding agent prior to January 1, 2023, pursuant to a  
securities lending transaction within the meaning of Notice  
2010-46. See also Notice 2020-2.  
A foreign intermediary or flow-through entity not receiving  
withholdable payments or reportable amounts that is holding  
an account with a participating FFI or registered  
For withholding under section 1446(f), a financial  
deemed-compliant FFI providing this form for purposes of  
documenting its chapter 4 status as an account holder. No  
withholding statement is required to be provided along with  
Form W-8IMY in this case. The entity may instead provide  
Form W-8BEN-E to document its chapter 4 status as an  
account holder of an FFI when it is not receiving withholdable  
payments or reportable amounts.  
institution incorporated or organized under the laws of a U.S.  
territory that is acting as an intermediary or that is a  
flow-through entity, to certify that it is acting as a U.S. person  
for amounts realized on sales of interests in PTPs.  
A financial institution incorporated or organized under the  
laws of a U.S. territory that is acting as an intermediary or that  
is a flow-through entity, to certify that it agrees to act as a  
U.S. person and as a nominee for distributions from PTPs  
under Regulations section 1.1446-4(b)(3) (or has otherwise  
provided (or will provide) a withholding statement for a  
distribution).  
A foreign partnership, foreign simple trust, or foreign  
grantor trust that is the seller of a life insurance contract (or  
interest therein) or a recipient of a reportable death benefit to  
establish its foreign status and to associate this form with any  
other applicable documentation for purposes of section  
6050Y or chapter 3. See Regulations sections 1.6050Y-3  
and 1.6050Y-4.  
A foreign partnership or a foreign simple or grantor trust to  
establish that it is a withholding foreign partnership or  
withholding foreign trust for purposes of chapters 3 and 4.  
This form may serve to establish foreign status for  
purposes of sections 1441, 1442, and 1446(a) or (f).  
However, any representations that items of income, gain,  
deduction, or loss are not effectively connected with a U.S.  
trade or business will be disregarded by a partnership  
receiving this form for purposes of section 1446(a) or (f), as  
the partnership will undertake its own analysis.  
A foreign partnership or a foreign simple or grantor trust to  
establish that it is a nonwithholding foreign partnership or  
nonwithholding foreign simple or grantor trust for reportable  
amounts and withholdable payments, to certify to its  
chapter 4 status (if required), to represent that the income is  
not effectively connected with a U.S. trade or business, and  
to certify that the form is being used to transmit withholding  
certificates and/or documentary evidence and that it has  
provided or will provide a withholding statement as required.  
Do Not Use Form W-8IMY If You Are Described  
Below  
A foreign partnership or foreign grantor trust to establish  
You are the beneficial owner (other than a QDD acting in  
that it is an upper-tier foreign partnership or foreign grantor  
trust for purposes of section 1446(a) and, except for a  
partnership that is a PTP, to represent that the form is being  
used to transmit withholding certificates and/or documentary  
evidence and that it has provided, or will provide, a  
withholding statement, as required.  
its QDD capacity or a QSL acting as a principal for substitute  
dividend payments) of U.S. source income (other than  
income that is effectively connected with the conduct of a  
trade or business within the United States ), and you need to  
establish that you are not a U.S. person, establish your  
chapter 4 status (if required), or claim a reduced rate of  
withholding on your own behalf under an income tax treaty (if  
applicable). Instead, submit Form W-8BEN or Form  
W-8BEN-E.  
A foreign partnership to establish that it is the transferor of  
an amount realized from the transfer of a partnership interest  
for purposes of section 1446(f) and, when applicable, to  
-3-  
Instructions for Form W-8IMY (Rev. 10-2021)  
You are a hybrid entity claiming treaty benefits on your  
When to provide Form W-8IMY to the withholding agent.  
Give Form W-8IMY to the person requesting it before income  
is paid, credited, or allocated to your account. If you do not  
provide this form, the withholding agent may have to withhold  
at the 30% rate (for an amount subject to withholding under  
chapter 3 or a withholdable payment under chapter 4),  
backup withhold, or withhold at the applicable rate for net  
effectively connected taxable income allocable to a foreign  
partner in a partnership under section 1446. Generally, a  
separate Form W-8IMY must be submitted to each  
own behalf (unless you are a QDD acting in your QDD  
capacity). Instead, provide Form W-8BEN-E to claim treaty  
benefits. However, if you are receiving a withholdable  
payment you may also be required to provide Form W-8IMY  
to establish your chapter 4 status (unless you are a  
disregarded entity) and the chapter 4 status of each of your  
partners, beneficiaries, or owners. See the Instructions for  
Form W-8BEN-E for more information about hybrid entities  
claiming treaty benefits.  
You are a foreign reverse hybrid entity (unless you are a  
withholding agent from whom you receive a payment.  
QDD acting in your QDD capacity or a QSL acting as a  
principal for substitute dividend payments) that is not  
claiming treaty benefits on behalf of your interest holders.  
Instead, provide Form W-8BEN-E on your own behalf.  
Expiration of Form W-8IMY. Generally, a Form W-8IMY  
remains valid until the status of the person whose name is on  
the certificate is changed in a way relevant to the certificate  
or there is a change in circumstances that makes the  
information on the certificate no longer correct. The indefinite  
validity period does not extend, however, to any other  
withholding certificates, documentary evidence, or  
You are the beneficial owner of income that is effectively  
connected with the conduct of a trade or business within the  
United States. Instead, provide Form W-8ECI.  
You are a nonresident alien individual who claims  
withholding statements associated with the certificate. If you  
are a QDD, the attachment associated with your Form  
W-8IMY used to claim treaty benefits (if applicable) is treated  
as a beneficial owner withholding certificate that is not valid  
indefinitely. For the validity period of a Form W-8IMY used by  
a QDD to claim an exemption from withholding that applies  
based on a QDD’s status as a foreign beneficial owner of the  
payment, see Regulations section 1.1441-1(e)(4)(ii)(A)(1).  
Change in circumstances. If a change in circumstances  
makes any information on the Form W-8IMY (or any  
documentation or withholding statement associated with the  
Form W-8IMY) you have submitted incorrect for purposes of  
chapter 3 or chapter 4 (when relevant), you must notify the  
withholding agent within 30 days of the change in  
circumstances and provide the documentation required in  
Regulations section 1.1471-3(c)(6)(ii)(E)(2). You must  
update the information associated with Form W-8IMY as  
often as is necessary to enable the withholding agent to  
withhold at the appropriate rate on each payment and to  
report such income.  
exemption from withholding on compensation for  
independent or certain dependent personal services  
performed in the United States. Instead, provide Form 8233  
or Form W-4.  
You are a disregarded entity, other than a hybrid entity that  
is a disregarded entity claiming treaty benefits on your own  
behalf (see above bullet). Instead, the single owner (if a  
foreign person) should provide the appropriate Form W-8  
based on the single owner's status. If you are a disregarded  
entity that is a QDD acting in your QDD capacity, your single  
owner (whether or not a QDD) should provide Form W-8IMY  
as a QI.  
You are a QI receiving payments of U.S. source income  
that you beneficially own other than payments received as a  
QDD in respect of potential section 871(m) transactions or  
underlying securities or received as a QSL acting as a  
principal in a security lending or sale-repurchase transaction  
(that is, you are receiving payments that you beneficially own  
that are not covered by your QI agreement). Instead, provide  
the appropriate Form W-8 based on your status for those  
payments you beneficially own.  
See Regulations sections 1.1441-1(e)(4)(ii)(D) for the  
definition of a change in circumstances for purposes of  
chapter 3 and Regulations section 1.1471-3(c)(6)(ii)(E) for  
the definition of a change in circumstances for purposes of  
chapter 4.  
You are 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 115(2),  
501(c), 892, 895, or 1443(b), and, if required, claiming an  
exemption from chapter 4 withholding. Instead, provide Form  
W-8EXP. However, these entities should use Form  
W-8BEN-E instead if they are claiming treaty benefits or are  
providing the form only to claim exempt recipient status for  
Form 1099 and backup withholding purposes.  
With respect to an FFI claiming a chapter 4 status  
under an applicable IGA, a change in circumstances  
!
CAUTION  
includes when the jurisdiction where the FFI is  
organized or resident (or the jurisdiction where a disregarded  
entity or branch of an FFI is organized, identified in Part II of  
the form) was included on the list of jurisdictions treated as  
having an intergovernmental agreement in effect and is  
removed from that list or when the FATCA status of the  
jurisdiction changes (for example, from Model 2 to Model 1).  
The list of agreements is maintained at www.treasury.gov/  
Giving Form W-8IMY to the withholding agent. Do not  
send Form W-8IMY to the IRS. Instead, give it to the person  
who is requesting it. Generally, this will be the person from  
whom you receive the payment, the person who credits your  
account, or a partnership that allocates income to you. If you  
are an account holder of an FFI, the FFI may request this  
form from you to document the status of your account for  
chapter 4 purposes.  
Definitions  
Account. With respect to QI, including a QI acting as a  
QDD, an account is defined in section 2.01 of the QI  
Agreement.  
Account holder. An account holder is generally the person  
listed or identified as the holder or owner of a financial  
account (other than an agent or nominee that is not an FFI).  
You may provide a single Form W-8IMY if you have  
multiple branches receiving payments from the same  
withholding agent rather than separate Forms  
TIP  
W-8IMY to identify each branch receiving payments  
associated with the form. In such a case, you should provide  
a schedule that includes all required information for each  
branch. See the instructions for Part II.  
-4-  
Instructions for Form W-8IMY (Rev. 10-2021)  
For example, if a partnership is listed as the holder or owner  
of a financial account, then the partnership is the account  
holder rather than the partners of the partnership. However,  
an account that is held by a disregarded entity is treated as  
held by the person owning the entity. With respect to a QI  
acting as a QDD, see section 2.02 of the QI Agreement for  
the definition of account holder.  
Amount realized. For purposes of section 1446(f), an  
amount realized on the transfer of an interest in a partnership  
other than a PTP is determined under section 1001 (including  
Regulations sections 1.1001-1 through 1.1001-5) and section  
752 (including Regulations sections 1.752-1 through  
to a foreign partnership are generally the partners in the  
partnership, provided that the partner is not itself a  
partnership, foreign simple or grantor trust, nominee, or other  
agent. The beneficial owners of income paid to a foreign  
simple trust (that is, a foreign trust that is described in section  
651(a)) are generally the beneficiaries of the trust, if the  
beneficiary is not itself a foreign partnership, foreign simple  
or grantor trust, nominee, or other agent. The beneficial  
owners of income paid to a foreign grantor trust (that is, a  
foreign trust to the extent that all or a portion of the income of  
the trust is treated as owned by the grantor or another person  
under sections 671 through 679) are the persons treated as  
the owners of the trust. The beneficial owner of income paid  
to a foreign complex trust (that is, a foreign trust that is not a  
foreign simple trust or foreign grantor trust) is the trust itself.  
1.752-7). See Regulations section 1.1446(f)-2(c)(2). An  
amount realized on the transfer of a PTP interest is the  
amount of gross proceeds (as defined in Regulations section  
1.6045-1(d)(5)) paid or credited to a partner or broker (as  
applicable) that is a transferor of the interest. The amount  
realized on a PTP distribution is the amount of the distribution  
reduced by the portion of the distribution that is attributable to  
the cumulative net income of the partnership (as determined  
under Regulations section 1.1446(f)-4(c)(2)(iii)).  
Amounts subject to withholding. Generally, an amount  
subject to chapter 3 withholding is an amount from sources  
within the United States that is fixed or determinable annual  
or periodical (FDAP) income (including such an amount on a  
PTP distribution unless indicated otherwise). FDAP income is  
all income included in gross income, including interest (as  
well as OID), dividends (including dividend equivalents),  
rents, royalties, and compensation. Amounts subject to  
chapter 3 withholding do not include amounts that are not  
FDAP, such as most gains from the sale of property  
(including market discount and option premiums), as well as  
other specific items of income described in Regulations  
section 1.1441-2 (such as interest on bank deposits and  
short-term OID).  
Generally, these beneficial owner rules apply for purposes  
of sections 1441, 1442, and 1446(a) and (f), except that  
sections 1446(a) and (f) require a foreign simple trust to  
provide a Form W-8 on its own behalf rather than on behalf of  
the beneficiary of such trust.  
The beneficial owner of income paid to a foreign estate is  
the estate itself.  
A payment to a U.S. partnership, U.S. trust, or U.S. estate  
is treated as a payment to a U.S. payee. A U.S. partnership,  
trust, or estate should provide the withholding agent with a  
Form W-9. However, for purposes of section 1446(a), a U.S.  
grantor trust or disregarded entity shall not provide the  
withholding agent a Form W-9 pertaining to itself. Instead,  
the entity must provide a Form W-8 or Form W-9 pertaining  
to each grantor or owner, as appropriate, and in the case of a  
trust, a statement identifying the portion of the trust treated as  
owned by each such person. For purposes of section  
1446(f), the grantor or owner must provide a Form W-8 or  
Form W-9 to certify its status and the amount realized  
allocable to the grantor or owner, which, alternatively, can be  
provided by the U.S. grantor trust on behalf of a grantor or  
owner.  
Broker. A person described in Regulations section  
1.1446(f)-1(b)(1) when referenced in connection with a  
transfer of a PTP interest.  
Chapter 3. Chapter 3 of the Internal Revenue Code  
(Withholding of Tax on Nonresident Aliens and Foreign  
Corporations), excluding sections 1445 and 1446.  
Amounts subject to chapter 4 withholding are payments of  
U.S. source FDAP income that are withholdable payments as  
defined in Regulations section 1.1473-1(a) and to which no  
exception under Regulations section 1.1473-1(a)(4) applies  
(for example, certain nonfinancial payments are excepted  
from the definition of withholdable payment). The exemptions  
from withholding provided for under chapter 3 are not  
applicable when determining whether withholding applies  
under chapter 4.  
Chapter 3 withholding rate pool. A payment of a single  
type of income, based on the categories of income reported  
on Form 1042-S (for example, interest or dividends), that is  
not subject to withholding under chapter 4 but is subject to a  
single rate of withholding and is paid to foreign persons or, in  
the case of a zero-percent pool, U.S. exempt recipients not  
included in a separate pool of exempt recipients.  
Chapter 4. Chapter 4 of the Internal Revenue Code (Taxes  
to Enforce Reporting on Certain Foreign Accounts).  
Chapter 4 contains sections 1471 through 1474.  
Chapter 4 status. A person’s status as a U.S. person,  
specified U.S. person, foreign individual, participating FFI,  
deemed-compliant FFI, restricted distributor, exempt  
beneficial owner, nonparticipating FFI, territory financial  
institution, excepted Non-Financial Foreign Entity (NFFE) or  
passive NFFE.  
Chapter 4 withholding rate pool. A pool identified on a  
withholding statement provided by an intermediary or  
flow-through entity with respect to a withholdable payment  
that is allocated to payees that are nonparticipating FFIs. The  
For purposes of section 1446(a), the amount subject to  
withholding is the foreign partner’s share of the partnership’s  
effectively connected taxable income. For purposes of  
section 1446(f), the amount subject to withholding is the  
amount realized on the transfer of a partnership interest.  
Beneficial owner. For payments other than those for which  
a reduced rate of, or exemption from, withholding is claimed  
under an income tax treaty, the beneficial owner of income is  
generally the person who is required under U.S. tax  
principles to include the payment in gross income on a tax  
return. A person is not a beneficial owner of income,  
however, to the extent that person is receiving the income as  
a nominee, agent, or custodian, or to the extent the person is  
a conduit whose participation in a transaction is disregarded.  
In the case of amounts paid that do not constitute income,  
beneficial ownership is determined as if the payment were  
income.  
Foreign partnerships, foreign simple trusts, and foreign  
grantor trusts are not the beneficial owners of income paid to  
the partnership or trust. The beneficial owners of income paid  
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Instructions for Form W-8IMY (Rev. 10-2021)  
term chapter 4 withholding rate pool also includes a pool  
identified on an FFI withholding statement provided by a  
participating FFI or registered deemed-compliant FFI with  
respect to a withholdable payment that is allocated to a class  
of recalcitrant account holders as described in Regulations  
section 1.1471- 4(d)(6) (or with respect to an FFI that is a QI,  
a single pool of recalcitrant account holders without the need  
to subdivide into each class of recalcitrant account holder),  
including a pool of account holders to which the escrow  
procedures for dormant accounts apply. Finally, a chapter 4  
withholding rate pool also includes a pool of U.S. persons  
included in a U.S. payee pool described in Regulations  
section 1.6049-4(c)(4) provided by a participating FFI  
(including a reporting Model 2 FFI), a registered  
For purposes of chapter 4, exceptions are provided for  
accounts such as certain tax-favored savings accounts, term  
life insurance contracts, accounts held by estates, escrow  
accounts, and certain annuity contracts. See Regulations  
section 1.1471-5(b)(2). Accounts may also be excluded from  
the definition of financial account under an applicable IGA.  
Financial institution. A financial institution generally  
means an entity that is a depository institution, custodial  
institution, investment entity, or an insurance company (or  
holding company of an insurance company) that issues cash  
value insurance or annuity contracts. See Regulations  
section 1.1471-5(e).  
Fiscally transparent entity. An entity is treated as fiscally  
transparent with respect to an item of income to the extent  
that the interest holders in the entity must, on a current basis,  
take into account separately their shares of an item of income  
paid to the entity, whether or not distributed, and must  
determine the character of the items of income as if they  
were realized directly from the sources from which realized  
by the entity. For example, partnerships, common trust funds,  
and simple trusts or grantor trusts are generally considered  
to be fiscally transparent with respect to items of income  
received by them.  
Flow-through entity. A foreign partnership (other than a  
withholding foreign partnership), a foreign simple or foreign  
grantor trust (other than a withholding foreign trust), or, for  
payments for which a reduced rate of withholding is claimed  
under an income tax treaty, any entity to the extent the entity  
is considered to be fiscally transparent with respect to the  
payment by an interest holder’s jurisdiction.  
deemed-compliant FFI (including a reporting Model 1 FFI), or  
a QI.  
Deemed-compliant FFI. Under section 1471(b)(2), certain  
FFIs are deemed to comply with the regulations under  
chapter 4 without the need to enter into an FFI agreement  
with the IRS. However, certain deemed-compliant FFIs are  
required to register with the IRS and obtain a GIIN. These  
FFIs are referred to as registered deemed-compliant FFIs.  
See Regulations section 1.1471-5(f)(1) and also an  
applicable IGA for entities treated as registered  
deemed-compliant FFIs.  
Disclosing QI. For purposes of section 1446(a) or (f), a QI  
that provides with its withholding statement the specific  
payee documentation referenced in Regulations section  
1.1446(f)-4(a)(7)(iii) (for an amount realized) or Regulations  
section 1.1446-4(e)(4) (for withholding on a PTP distribution  
under section 1446(a)) instead of the chapter 3 withholding  
rate pool information otherwise permitted to be included on  
the withholding statement. A QI that acts as a disclosing QI  
for a payment must act as a disclosing QI for the entire  
payment.  
Disregarded entity. A business entity that has a single  
owner and is not a corporation under Regulations section  
301.7701-2(b) is disregarded as an entity separate from its  
owner. A disregarded entity does not submit Form W-8IMY to  
a withholding agent or FFI. Instead, the owner of such entity  
provides the appropriate documentation (for example, a  
Form W-8BEN-E if the owner is a foreign entity that is not a  
QDD). However, if a disregarded entity receiving a  
withholdable payment is an FFI outside the single owner’s  
country of organization or has its own GIIN, see the  
instructions to Part II of Form W-8IMY for when to provide the  
chapter 4 status of the disregarded entity receiving the  
payment.  
Foreign financial institution (FFI). A foreign entity that is a  
financial institution.  
Foreign person. A foreign person includes a nonresident  
alien individual, a foreign corporation, a foreign partnership, a  
foreign trust, a foreign estate, and any other person that is  
not a U.S. person. It also includes a foreign branch or office  
of a U.S. financial institution or U.S. clearing organization if  
the foreign branch is a qualified intermediary. Generally, a  
payment to a U.S. branch of a foreign person is a payment to  
a foreign person.  
Global intermediary identification number (GIIN). The  
identification number assigned to an entity that has  
registered with the IRS for chapter 4 purposes.  
Hybrid entity. Any person (other than an individual) that is  
treated as fiscally transparent (rather than as a beneficial  
owner) under the Code but is not treated as fiscally  
transparent by a country with which the United States has an  
income tax treaty. Hybrid entity status is relevant for claiming  
treaty benefits for purposes of chapter 3. A hybrid entity,  
may, however, be considered the payee for purposes of  
chapter 4 (see Regulations section 1.1471-3(a) defining who  
is a payee of a withholdable payment). See the special  
instructions for hybrid entities, earlier, under Who Must  
Provide Form W-8IMY, and Regulations section 1.1471-3(d)  
for the documentation requirements with respect to entities  
receiving withholdable payments.  
Certain entities that are disregarded for U.S. tax purposes  
may nevertheless be treated as treaty residents for purposes  
of claiming treaty benefits under an applicable tax treaty (see  
the definition of Hybrid entity, later). See Form W-8BEN-E  
and the accompanying instructions for more information  
about a hybrid entity claiming treaty benefits on its own  
behalf as a resident of a treaty jurisdiction.  
Financial account. A financial account includes:  
A depository account maintained by an FFI;  
A custodial account maintained by an FFI;  
Equity or debt interests (other than interests regularly  
Intergovernmental Agreement (IGA). A Model 1 IGA or a  
Model 2 IGA. For a list of jurisdictions treated as having in  
effect a Model 1 or Model 2 IGA, go to www.treasury.gov/  
traded on an established securities market) in investment  
entities and certain holding companies, treasury centers, or  
financial institutions;  
Certain cash value insurance contracts; and  
Annuity contracts.  
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Instructions for Form W-8IMY (Rev. 10-2021)  
 
A Model 1 IGA means an agreement between the United  
States or the Treasury Department and a foreign government  
or one or more agencies to implement FATCA through  
reporting by FFIs to such foreign government or agency  
thereof, followed by automatic exchange of the reported  
information with the IRS. An FFI in a Model 1 IGA jurisdiction  
that performs account reporting to the jurisdiction’s  
foregoing, a QDD may not act as a QSL for potential section  
871(m) transactions, except with respect to a payment on a  
securities lending or sale-repurchase transaction for which  
the QI has determined that it is acting as an intermediary for  
the payment. While Notice 2010-46 was obsoleted, Notice  
2020-2 permits withholding agents to apply the transition  
rules described in Notice 2010-46 for payments made in  
2021 and 2022.  
government is referred to as a reporting Model 1 FFI.  
Nonqualified intermediary. Any intermediary that is not  
a U.S. person and that is not a qualified intermediary.  
A Model 2 IGA means an agreement or arrangement  
between the United States or the Treasury Department and a  
foreign government or one or more agencies to implement  
FATCA through reporting by FFIs directly to the IRS in  
accordance with the requirements of an FFI agreement,  
supplemented by the exchange of information between such  
foreign government or agency thereof and the IRS. An FFI in  
a Model 2 IGA jurisdiction that registered with the IRS to  
obtain a GIIN and agreed to comply with the terms of an FFI  
agreement with respect to a branch is treated as a  
participating FFI but may be referred to as a reporting  
Model 2 FFI.  
Modified amount realized. In the case of an amount  
realized under section 1446(f) received by a transferor that is  
a foreign partnership, the amount determined under  
Regulations section 1.1446(f)-4(c)(2)(ii) (for a transfer of a  
PTP interest) or under Regulations section 1.1446(f)-2(c)(2)  
(iv) (for a transfer of an interest in a partnership other than a  
PTP).  
Nominee. When referenced in connection with a PTP  
distribution, a person that holds an interest in a PTP on  
behalf of a foreign person and that is either a U.S. person, a  
QI that assumes primary withholding responsibility for a PTP  
distribution, or a U.S. branch of a foreign person (or territory  
financial institution) that agrees to be treated as a U.S.  
person with respect to the distribution. See Regulations  
section 1.1446-4(b)(3).  
The term reporting IGA FFI refers to both reporting  
Model 1 FFIs and reporting Model 2 FFIs.  
Intermediary. Any person that 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 person that is a party to a  
withholding agreement with the IRS (described in  
Regulations section 1.1441-1(e)(5)(iii)) and is:  
Nonreporting IGA FFI. An FFI that is a resident of, or  
located or established in, a Model 1 or Model 2 IGA  
jurisdiction that meets the requirements of:  
A nonreporting financial institution described in a specific  
category in Annex II of the Model 1 or Model 2 IGA;  
A registered deemed-compliant FFI described in  
A foreign financial institution (other than a U.S. branch of  
an FFI) that is a participating FFI (including a reporting Model  
2 FFI), a registered deemed-compliant FFI (including an FFI  
treated as a deemed-compliant FFI under an applicable IGA  
subject to due diligence and reporting requirements similar to  
those applicable to a registered deemed-compliant FFI under  
Regulations section 1.1471-5(f)(1), including the requirement  
to register with the IRS), or any other category of FFI  
identified in the QI agreement;  
Regulations section 1.1471-5(f)(1)(i)(A) through (F);  
A certified deemed-compliant FFI described in  
Regulations section 1.1471-5(f)(2)(i) through (v); or  
An exempt beneficial owner described in Regulations  
section 1.1471-6.  
Nonwithholding foreign partnership, simple trust, or  
grantor trust. A nonwithholding foreign partnership is any  
foreign partnership other than a withholding foreign  
partnership. A nonwithholding foreign simple trust is any  
foreign simple trust that is not a withholding foreign trust. A  
nonwithholding foreign grantor trust is any foreign grantor  
trust that is not a withholding foreign trust.  
Participating FFI. An FFI that has agreed to comply with the  
terms of an FFI agreement with respect to all branches of the  
FFI, other than a branch that is a reporting Model 1 FFI or a  
U.S. branch. The term participating FFI also includes a  
reporting Model 2 FFI and a QI branch of a U.S. financial  
institution, unless such branch is a reporting Model 1 FFI.  
Payee. A payee is generally a person to whom a payment is  
made, regardless of whether such person is the beneficial  
owner. For a payment made to a financial account, the payee  
is generally the holder of the financial account. However,  
under certain circumstances a person who receives a  
payment will not be considered the payee. For purposes of  
chapter 3, see Regulations section 1.1441-1(b)(2) and for  
chapter 4, see Regulations section 1.1471-3(a)(3).  
Publicly traded partnership (PTP). A PTP is an entity that  
has the same meaning as in section 7704 and Regulations  
sections 1.7704-1 through 1.7704-4 but does not include a  
PTP treated as a corporation under that section.  
A foreign person that is a home office or has a branch that  
is an eligible entity (as described in Regulations section  
1.1441-1(e)(6)(ii);  
A foreign branch or office of a U.S. financial institution or a  
foreign branch or office of a U.S. clearing organization; or  
A foreign entity not described above that the IRS accepts  
as a qualified intermediary.  
Qualified derivatives dealer (QDD). A QI that is an  
eligible entity that agrees to meet the requirements of  
Regulations section 1.1441-1(e)(6)(i) and the QI agreement  
and has been approved by the IRS to so act. An eligible  
entity is defined in Regulations section 1.1441-1(e)(6)(ii).  
The home office or branch, as applicable, that is a QDD  
must represent itself as a QDD on its Form W-8IMY and  
separately identify the home office or branch as a recipient  
on a withholding statement (if necessary). Each home office  
or branch that obtains QDD status is treated as a separate  
QDD.  
Qualified securities lender (QSL). Notice 2010-46,  
provided rules for QSLs acting with respect to payments of  
substitute dividends. A QSL that is a QI should certify to its  
QSL status in Part III of this form, regardless of whether it is  
acting as a principal or an agent with respect to its QSL  
transactions. A QSL that is not a QI, including a QSL acting  
as a principal with respect to QSL transactions, should certify  
its QSL status in Part IV of this form. Notwithstanding the  
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Instructions for Form W-8IMY (Rev. 10-2021)  
 
any foreign intermediary, foreign partnership, and U.S.  
PTP distribution. A PTP distribution is a distribution made  
branches of certain foreign banks and insurance companies.  
by a PTP.  
For purposes of section 1446(a), in general, the  
withholding agent is the partnership conducting the trade or  
business in the United States. For purposes of section  
1446(a), the withholding agent for a PTP may be the  
partnership or a nominee for a distribution holding an interest  
on behalf of a foreign person. See Regulations section  
1.1446-4.  
Withholding foreign partnership (WP) or withholding  
foreign trust (WT). A WP or WT is a foreign partnership or  
a foreign simple or grantor trust that has entered into a  
withholding agreement with the IRS in which it agrees to  
assume primary withholding responsibility for purposes of  
chapter 4 and sections 1441 through 1443 for all payments  
that are made to its partners, beneficiaries, or owners, except  
as otherwise provided in the withholding agreement. A WP  
also includes a foreign reverse hybrid entity that has entered  
into a withholding agreement.  
PTP interest. A PTP interest is an interest in a PTP if the  
interest is publicly traded on an established securities market  
or is readily tradable on a secondary market (or the  
substantial equivalent thereof).  
Reportable amount. Solely for purposes of the statements  
required to be attached to Form W-8IMY, a reportable  
amount is an amount subject to withholding under chapter 3,  
U.S. source deposit interest (including original issue  
discount), and U.S. source interest or original issue discount  
on the redemption of short-term obligations. It does not  
include payments on deposits with banks and other financial  
institutions that remain on deposit for 2 weeks or less or  
amounts received from the sale or exchange (other than a  
redemption) of a short-term obligation that is effected outside  
the United States. It also does not include amounts of original  
issue discount arising from a sale and repurchase transaction  
completed within a period of 2 weeks or less, or amounts  
described in Regulations section 1.6049-5(b)(7), (10), or (11)  
(relating to certain obligations issued in bearer form).  
Reverse hybrid entity. Any person (other than an  
individual) that is not fiscally transparent under U.S. tax law  
principles but that is fiscally transparent under the laws of a  
jurisdiction with which the United States has an income tax  
treaty.  
Territory financial institution. A financial institution that is  
incorporated or organized under the laws of any U.S.  
territory. However, an investment entity that is not also a  
depository institution, custodial institution, or specified  
insurance company is not a territory financial institution. A  
territory financial institution acting as an intermediary or that  
is a flow-through entity may agree to be treated as a U.S.  
person under Regulations section 1.1441-1(b)(2)(iv)(A), for  
purposes of withholding on a PTP distribution as a nominee  
under Regulations section 1.1446-4(b)(3), or for an amount  
realized under section 1446(f).  
Transfer. A sale, exchange, or other disposition of an  
interest in a partnership, and includes a distribution from a  
partnership to a partner, as well as a transfer treated as a  
sale or exchange under section 707(a)(2)(B).  
Transferee. Any person, foreign or domestic, that acquires  
a partnership interest through a transfer, and includes a  
partnership that makes a distribution.  
Transferor. A transferor is any person, foreign or domestic,  
that transfers an interest in a partnership. In the case of a  
trust, to the extent all or a portion of the income of the trust is  
treated as owned by the grantor or another person under  
sections 671 through 679, the term transferor means the  
grantor or other person.  
Withholding statement. A withholding statement for a  
reportable amount provides an allocation (by income type) to  
each payee (or withholding rate pool, if applicable, or other  
pool of payees to the extent permitted under the section 1441  
and chapter 4 regulations) of each payment an intermediary  
or flow-through entity receives. For purposes of section  
1446(a), a withholding statement provided by an upper-tier  
foreign partnership (or foreign grantor trust to a lower-tier  
partnership or intermediary receiving the amount on behalf of  
the foreign partnership or grantor trust) provides an allocation  
of the effectively connected income to each partner or owner  
in the upper-tier partnership or the trust. For purposes of  
section 1446(f), a withholding statement provided by an  
intermediary for an amount realized on the transfer of a PTP  
interest provides an allocation of the amount realized to each  
transferor of the PTP interest or to a chapter 3 or 4  
withholding rate pool when permitted under Regulations  
section 1.1446(f)-4(a)(7). The withholding statement  
provided by an intermediary for a PTP distribution provides  
allocation information with respect to each partner receiving  
a distribution of an amount subject to withholding under  
section 1446(a) or (f), with respect to each beneficial owner  
or payee receiving an amount subject to withholding under  
chapter 3 or 4 on the distribution (such as a beneficiary of a  
partner in the PTP that is a simple trust receiving a payment  
subject to chapter 3 withholding), or with respect to a  
chapter 3 or 4 withholding rate pool as permitted (including a  
QI not assuming withholding responsibility for the distribution,  
but excluding an allocation to a U.S. partner or when the QI  
acts as a disclosing QI). For the limitation on when a  
nonqualified intermediary may provide a withholding  
statement for an amount realized, however, see Withholding  
later. Also, see Regulations section 1.1446-4(d)(1) for when  
the amounts subject to withholding on a PTP distribution  
cannot be determined from a qualified notice issued by the  
PTP. For a withholding statement provided by a foreign  
partnership to claim a modified amount realized for purposes  
of section 1446(f), see the instructions for Line 21d, later.  
Underlying security. The term underlying security is  
defined in Regulations section 1.871-15(a)(15).  
Withholdable payment. The term withholdable payment is  
defined in Regulations section 1.1473-1(a).  
Withholding agent. Any person, U.S. or foreign, that has  
control, receipt, custody, disposal, or payment of U.S. source  
FDAP income subject to chapter 3 or a withholdable payment  
under chapter 4 is a withholding agent. The withholding  
agent may be an individual, corporation, partnership, trust,  
association, or any other entity, including (but not limited to)  
The withholding statement forms an integral part of the  
withholding certificate, and the penalties of perjury statement  
provided on the withholding certificate shall apply to the  
withholding statement. The withholding statement may be  
provided in any manner upon which the intermediary or the  
flow-through entity and the withholding agent mutually agree,  
including electronically if certain safeguards concerning  
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Instructions for Form W-8IMY (Rev. 10-2021)  
 
electronic transmission are met. A withholding statement also  
provides information required for purposes of chapter 4 if the  
intermediary or flow-through entity is receiving a withholdable  
payment, in which case the entity must provide an FFI  
withholding statement, chapter 4 withholding statement, or  
exempt beneficial owner withholding statement (as  
a treaty should check the appropriate box (including  
“Withholding foreign partnership” or “Withholding foreign  
trust” if the entity has entered into a withholding agreement).  
A partnership or grantor trust submitting Form W-8IMY solely  
because it is allocated income effectively connected with a  
U.S. trade or business as a partner in a partnership should  
check the box for nonwithholding foreign partnership or  
nonwithholding foreign grantor trust and, if it is submitting or  
will submit documentation for its partners or owners, it should  
complete Part VIII.  
applicable). See Regulations section 1.1471-3(c)(3)(iii)(B).  
Additional information is required for a withholding statement  
from a QDD. See QDD withholding statement, later.  
Form W-8IMY may be provided to satisfy  
Specific Instructions  
documentation requirements for purposes of  
withholding on certain partnership allocations to  
TIP  
Part I — Identification of Entity  
foreign partners under section 1446(a). Section 1446(a)  
generally requires withholding when a partnership is  
conducting a trade or business in the United States and  
allocates taxable income effectively connected with that  
trade or business (ECTI) to foreign persons that are partners  
in the partnership. Section 1446(a) can also apply when  
certain income is treated as effectively connected income of  
the partnership and is so allocated.  
Line 1. Enter your name. By doing so, you are representing  
to the payer or withholding agent that you are not the  
beneficial owner of the amounts that will be paid to you  
(unless you are acting as a QDD or QSL for certain payments  
associated with this form or you are a QI acting with respect  
to payments of substitute interest, as permitted by the QI  
agreement). If you are a disregarded entity, do not enter the  
business name of the disregarded entity here. Instead, enter  
the legal name of the entity that owns the disregarded entity  
(looking through multiple disregarded entities, if applicable).  
An upper-tier foreign partnership that is allocated ECTI as a  
partner in a lower-tier partnership (LTP) may request, if  
certain requirements are met, the lower-tier partnership  
perform withholding under section 1446(a) on that ECTI  
taking into account the status of the partners in the upper-tier  
partnership. Upper-tier PTPs are not permitted to use these  
look-through rules. Generally, this is accomplished by the  
upper-tier partnership submitting withholding certificates of  
its partners (for example, Form W-8BEN) along with a Form  
W-8IMY, which identifies itself as a partnership, and  
identifying the manner in which ECTI of the upper-tier  
partnership will be allocated to the partners. Domestic  
non-PTPs that meet similar requirements may be able to  
elect to apply look-through rules, if the LTP agrees, by using  
Form W-9, instead of a W-8IMY. For further information, see  
Regulations section 1.1446-5. A foreign grantor trust that is  
allocated ECTI as a partner in a partnership should provide  
the withholding certificates of its grantor (for example, Form  
W-8BEN) along with its Form W-8IMY which identifies the  
trust as a foreign grantor trust. See Regulations section  
1.1446-1(c)(2)(ii)(E) for the rules requiring it to provide  
additional documentation to the partnership.  
Line 2. If you are a corporation, enter the country of  
incorporation. If you are another type of entity, enter the  
country under whose laws you are created, organized, or  
governed.  
Line 3. If you are a disregarded entity receiving a payment,  
enter your name (if required). You are required to complete  
line 3 if you are a disregarded entity receiving a withholdable  
payment or hold an account with an FFI requesting this form  
and you:  
Have registered with the IRS and been assigned a GIIN  
associated with the legal name of the disregarded entity; and  
Are a reporting Model 1 FFI or reporting Model 2 FFI.  
If you are a disregarded entity that is a QDD, identify the  
QDD by the name used by the QDD for the QI application.  
For instructions for identifying the names of multiple QDDs,  
If you are not required to provide the legal name of  
the disregarded entity, however, you may want to  
!
CAUTION  
notify the withholding agent that you are a  
Line 5. Check the one box that applies to your chapter 4  
status. You are only required to provide a chapter 4 status if  
you are acting as an intermediary with respect to a  
disregarded entity receiving a payment or maintaining an  
account by indicating the name of the disregarded entity on  
line 10.  
withholdable payment, you are a flow-through entity receiving  
a withholdable payment on behalf of your owners (including a  
reverse hybrid entity providing documentation on behalf of its  
owners to claim treaty benefits), you are providing a  
withholding statement associated with this form that allocates  
a portion of the payment to a chapter 4 withholding rate pool  
of U.S. payees with respect to your direct account holders  
(as described in Regulations section 1.6049-4(c)(4)), you are  
providing this form to an FFI requesting this form to  
document your chapter 4 status, or you are a QI (including a  
QDD), WP, or WT. If you are a U.S. branch that does not  
agree to be treated as a U.S. person and that does not make  
the certification on line 19c, you should check  
Line 4. Complete this line to establish your entity status for  
purposes of chapter 3. Check the one box that applies. If you  
are a foreign partnership receiving the payment on behalf of  
your partners, check the “Withholding foreign partnership”  
box or the “Nonwithholding foreign partnership” box,  
whichever is appropriate. If you are a foreign simple trust or  
foreign grantor trust receiving the payment on behalf of your  
beneficiaries or owners, check the “Withholding foreign trust”  
box, the “Nonwithholding foreign simple trust” box, or the  
“Nonwithholding foreign grantor trust” box, whichever is  
appropriate. If you are a foreign partnership (or a foreign  
trust) receiving a payment on behalf of persons other than  
your partners (or beneficiaries or owners), check the  
“Qualified intermediary” box or the “Nonqualified  
nonparticipating FFI; otherwise, leave line 5 blank. By  
checking a box on this line, you are representing that you  
qualify for this classification.  
intermediary” box, whichever is appropriate. A foreign  
reverse hybrid entity that is providing documentation from its  
interest holders to claim a reduced rate of withholding under  
-9-  
Instructions for Form W-8IMY (Rev. 10-2021)  
For most of the chapter 4 classifications, you are  
required to complete additional certifications found in  
Parts IX through XXVIII. Complete the appropriate  
appropriate box and enter the EIN that was issued to you in  
such capacity (your “QI-EIN,” “WP-EIN,” or “WT-EIN”). If you  
are not acting in that capacity, you must use your U.S.  
taxpayer identification number (TIN), if any, that is not your  
QI-EIN, WP-EIN, or WT-EIN.  
TIP  
part of this form certifying that you meet the conditions of the  
status indicated on line 5 (as defined under Regulations  
sections 1.1471-5 or 1.1471-6). Complete the required  
portion of this form before signing and providing it to the  
withholding agent.  
A nonqualified intermediary, a nonwithholding foreign  
partnership, or a nonwithholding foreign simple or grantor  
trust is generally not required to provide a U.S. TIN.  
However, an upper-tier partnership or trust that is allocated  
ECTI (or receives a PTP distribution attributable to ECTI) as a  
partner in a lower-tier partnership is required to provide a  
U.S. TIN. The requirement to include a U.S. TIN in this line 8  
also applies to a foreign partnership or a foreign trust  
receiving an amount realized from a transfer of an interest in  
a partnership conducting a trade or business in the United  
States. Additionally, a QSL providing this form with respect to  
a U.S. source substitute dividend must provide an EIN (a  
QI-EIN if the QSL is a QI).  
FFIs Covered by IGAs and Related Entities  
A reporting FFI resident in, or established under the laws of,  
a jurisdiction covered by a Model 1 IGA should check  
“Reporting Model 1 FFI.” A reporting FFI resident in, or  
established under the laws of, a jurisdiction covered by a  
Model 2 IGA should check “Reporting Model 2 FFI.” If you  
are treated as a registered deemed-compliant FFI under an  
applicable IGA, you should check “Nonreporting IGA FFI”  
rather than “registered deemed-compliant FFI” and provide  
your GIIN. See the specific instructions for Part XIX. In  
general, if you are treated as a nonreporting IGA FFI under  
an applicable IGA, you should check “Nonreporting IGA FFI”  
even if you meet the qualifications for deemed-compliant  
status under the chapter 4 regulations. In such a case, you  
need not also check your applicable status under the  
regulations but should provide your GIIN on line 9. However,  
an owner documented FFI that is treated as a nonreporting  
IGA FFI under an applicable IGA must check  
Line 9a. Complete line 9a if you are a participating FFI  
(including a reporting Model 2 FFI), registered  
deemed-compliant FFI (including a reporting Model 1 FFI  
and a sponsored FFI described in Regulations section  
1.1471-5(f)(1)(i)(F)), direct reporting NFFE (including a  
sponsored direct reporting NFFE), or trustee of a trustee  
documented trust that is a foreign person, you are required to  
enter your GIIN (with regard to your country of residence) on  
line 9a. If you are a trustee of a trustee-documented trust and  
you are a foreign person, you should provide the GIIN that  
you received when you registered as a participating FFI or  
reporting Model 1 FFI. In addition, you must provide your  
GIIN on line 9a if you are a nonreporting IGA FFI that is: (1)  
treated as registered deemed-compliant under Annex II to an  
applicable Model 2 IGA, or (2) a registered  
“Owner-documented FFI” and complete Part XI. An FFI that  
is related to a reporting IGA FFI and that is treated as a  
nonparticipating FFI in its country of residence should check  
nonparticipating FFI on line 5. An FFI that is related to a  
reporting IGA FFI and that is a participating FFI,  
deemed-compliant FFI, or exempt beneficial owner under the  
U.S. Treasury regulations, or an applicable IGA should check  
the appropriate box depending on its chapter 4 status rather  
than the box for nonparticipating FFI.  
deemed-compliant FFI under Regulations section 1.1471-5(f)  
(1).  
If you are a QI acting as a QDD, you must provide your  
GIIN on line 9a if you have one.  
If you are an FFI in a jurisdiction treated as having an IGA  
in effect, you should not check “Participating FFI” and should  
check “Reporting Model 1 FFI” or “Reporting Model 2 FFI” as  
applicable.  
If you are a certified deemed-compliant FFI described in  
Part XIV of this form, provide the GIIN of your sponsoring  
entity on line 9a.  
If you are in the process of registering with the IRS as  
Pages/FATCA-Archive.aspx for a list of jurisdictions treated  
as having an IGA in effect.  
a participating FFI, registered deemed-compliant FFI  
(including a sponsored FFI), reporting Model 1 FFI,  
TIP  
reporting Model 2 FFI, direct reporting NFFE, sponsored  
direct reporting NFFE, or nonreporting IGA FFI but have not  
received a GIIN, you may complete line 9a by writing “applied  
for.” However, the person requesting this form from you must  
receive and verify your GIIN within 90 days.  
Line 6. Enter the permanent address of the entity identified  
on line 1. Your permanent residence address is the address  
in the country where you claim to be a resident for purposes  
of that country's income tax. Do not show the address of a  
financial institution (other than yourself), a post office box, or  
an address used solely for mailing purposes unless such  
address is the only permanent address you use and it  
appears in your organizational documents (that is, your  
registered address). If you do not have a tax residence in any  
country, the permanent residence address is where you  
maintain your principal office.  
If you are a disregarded entity that completed Part I, line 3,  
do not enter your GIIN on line 9a. Instead, enter it on line 13.  
Line 9b. Complete line 9b if you are a QDD that must  
provide a foreign taxpayer identification number (FTIN). For  
information on this requirement (and when an FTIN is not  
required), see QDD withholding statement, later.  
Line 10. You, or a withholding agent, may use this line to  
include any referencing information that is useful to the  
withholding agent in carrying out its reporting and withholding  
obligations. For example, a withholding agent who is required  
to associate a particular Form W-8BEN or Form W-8BEN-E  
with this Form W-8IMY may use line 10 for a referencing  
number or code that will make the association clear.  
Line 7. Enter your mailing address only if it is different from  
the address you show on line 6.  
Line 8. You must provide an employer identification number  
(EIN) if you are a U.S. branch or are a territory financial  
institution that certifies that it has agreed to be treated as a  
U.S. person for any payments associated with this Form  
W-8IMY.  
If you are acting as a QI (including a QDD), withholding  
foreign partnership, or withholding foreign trust, check the  
-10-  
Instructions for Form W-8IMY (Rev. 10-2021)  
If you are in the process of registering your branch  
with the IRS but have not received a GIIN, you may  
complete this line by writing “applied for.” However,  
Part II — Disregarded Entity or  
Branch Receiving Payment  
TIP  
the person requesting this form from you must receive and  
verify your GIIN within 90 days.  
Complete Part II for a disregarded entity that has its own GIIN  
and is receiving a withholdable payment or for a branch  
(including a branch that is a disregarded entity that does not  
have its own GIIN) operating in a jurisdiction other than the  
country of residence identified on line 2. For example,  
assume ABC Co., which is a participating FFI resident in  
Country A, operates through a branch in Country B (which is  
a Model 1 IGA jurisdiction) and the branch is treated as a  
reporting Model 1 FFI under the terms of the Country B  
Model 1 IGA. ABC Co. should not enter its GIIN on line 9a,  
and the Country B branch should complete this Part II by  
identifying itself as a reporting Model 1 FFI and providing its  
GIIN on line 13. If the Country B branch receiving the  
payment is a disregarded entity, you may be required to  
provide its legal name on line 3.  
Certification of Chapter 3 Status:  
Parts III Through VIII  
You should only complete one part from Parts III through VIII.  
Generally, if you are acting in multiple capacities, you should  
provide separate Forms W-8IMY for each capacity. For  
example, if you are acting as a QI for one account, but an  
NQI for another account, you should provide one Form  
W-8IMY in your capacity as a QI and a separate Form  
W-8IMY in your capacity as an NQI.  
You may, however, provide a single Form W-8IMY that  
covers more than one category of QI provided that you  
properly identify the accounts and/or transactions, as  
required, on a withholding statement. For example, if you are  
a QI that acts as both a QI and a QDD, you may provide a  
single Form W-8IMY with a withholding statement  
designating each type of account or transaction.  
If the disregarded entity receiving a withholdable  
payment has its own GIIN, Part II should be  
TIP  
completed regardless of whether it is in the same  
country as the single owner identified in Part I.  
If you have multiple branches/disregarded entities  
receiving payments from the same withholding agent and the  
information in Part I is the same for each branch/disregarded  
entity that will receive payments, you may provide (and a  
withholding agent may accept) a single Form W-8IMY with a  
separate schedule attached that includes all of the Part II  
information for each branch/disregarded entity rather than  
separate Forms W-8IMY to identify each branch receiving  
payments associated with the form. You must also provide  
the withholding agent with sufficient information to associate  
the payments with each branch/disregarded entity.  
Part III — Qualified Intermediary  
Line 14. Check the box on line 14 if you are a QI (whether or  
not you assume primary withholding responsibility) for the  
payments for which you are providing this form. By checking  
the box, you are certifying to the applicable statements  
contained on line 14. See the QI agreement for the definition  
of “account” for purposes of Part III.  
Line 15. Complete line 15 only if you are acting as a QI that  
is not a QDD. To the extent you are a QI acting as a QDD,  
see the instructions for line 16. If you are acting in both QI  
capacities, you should complete both lines 15 and 16 to the  
extent applicable.  
Line 15a. Check the box on line 15a if you have assumed  
primary withholding responsibility under both chapter 3 and  
chapter 4 with respect to the account(s) identified on a  
withholding statement attached to this form (or, if no  
withholding statement is attached to this form, for all  
accounts). The representation made in this box on line 15a  
may be made regardless of whether you assume primary  
withholding responsibility for a PTP distribution (by checking  
the box on line 15c) as the representation made on this  
line 15a does not apply to an amount subject to chapter 3  
withholding on a PTP distribution.  
Furthermore, the box on line 15a may be checked  
regardless of which boxes you check on lines 15b through  
15i for any accounts identified on a withholding statement.  
Line 15b. Check the box on line 15b if you have assumed  
primary withholding and reporting responsibilities under  
section 1446(f) for each payment of an amount realized on a  
sale of a PTP interest associated with each account identified  
on a withholding statement attached to this form for receiving  
such amounts (or, if no withholding statement is attached to  
this form, for all accounts).  
Line 15c. Check the box on line 15c if you have assumed  
primary withholding responsibility as a nominee for each  
distribution by a PTP that is associated with each account  
identified on a withholding statement attached to this form for  
receiving such distributions (or, if no withholding statement is  
attached to this form, for all accounts).  
If you are a QDD home office or you are a QI and have  
one or more QDD branches, do not complete Part II for any  
branches that are acting in their QDD capacities. Instead,  
provide the relevant branch information that you would  
otherwise provide on Part II (including the information  
required for chapter 4 purposes, as required) on your  
withholding statement.  
Line 11. Check the one box that applies. If no box applies  
to the disregarded entity, you do not need to complete Part II.  
If you check reporting Model 1 FFI, reporting Model 2 FFI, or  
participating FFI, you must complete line 13. If you are a  
branch of a reporting IGA FFI that cannot comply with the  
requirements of an applicable IGA or the regulations under  
chapter 4, you must check branch treated as nonparticipating  
FFI. If you are a QI that is an NFFE and a withholding agent  
requests your chapter 4 status, you may provide a statement  
certifying to your chapter 4 status as an NFFE.  
Line 12. Enter the address of the branch or disregarded  
entity.  
Line 13. If you are a reporting Model 1 FFI, a reporting  
Model 2 FFI, or a participating FFI, you must enter on line 13  
the GIIN of your branch that receives the payment. If you are  
a disregarded entity that completed Part I, line 3, of this form  
and are receiving payments associated with this form, enter  
your GIIN. Do not enter your GIIN (if any) on line 9a. If you  
are a U.S. branch, do not enter a GIIN on line 13.  
-11-  
Instructions for Form W-8IMY (Rev. 10-2021)  
 
Line 15d. Check the box on line 15d if you are a QI that is  
acting as a QSL with respect to payments associated with  
each account identified on a withholding statement attached  
to this form (or, if no withholding statement is attached to this  
form, for all accounts) that are U.S. source substitute  
dividends made in 2021 or 2022 by a party to a securities  
lending transaction (as described in Notice 2010-46) for  
which you are not acting as a QDD. See Notice 2020-2 and  
Qualified securities lender (QSL), earlier, for the limitation on  
when a QI is permitted to act as a QSL.  
Line 15e. Check the box on line 15e to certify that you are  
a QI that is assuming primary withholding responsibility under  
chapter 3 and chapter 4 and primary Form 1099 reporting  
and backup withholding responsibility with respect to all  
payments associated with this form that are U.S. source  
interest and substitute interest payments, as permitted by  
(and described in) the QI agreement. You may act as a QI  
with respect to such substitute interest payments under the  
QI agreement regardless of whether you are acting in a  
principal or intermediary capacity with respect to payments of  
interest and substitute interest you receive that are  
associated with this form and regardless of whether you act  
as a QDD or QSL.  
participating FFI, registered deemed-compliant FFI, or a  
qualified intermediary. See Regulations sections 1.1471-3(d)  
(4) and 1.1471-3(e) for more information on the requirements  
for documenting such chapter 4 statuses.  
A payment that is subject to chapter 3 withholding or  
that should be subject to chapter 4 withholding may  
!
CAUTION  
not be included in a U.S. payee pool that is described  
in Regulations section 1.6049-4(c)(4)(ii).  
Although, as a QI, you obtain withholding certificates or  
appropriate documentation from beneficial owners or  
payees, as specified in your QI agreement, you do not need  
to attach the certificates or documentation to this form unless  
you are acting as a disclosing QI with respect to an amount  
realized or PTP distribution. Also, to the extent you have not  
assumed primary Form 1099 reporting or backup withholding  
responsibility and are not permitted to allocate the payment  
to a chapter 4 withholding rate pool of U.S. payees under  
Regulations section 1.6049-4(c)(4)(iii), you must disclose the  
names of those U.S. persons for whom you receive  
reportable amounts and that are not exempt recipients (as  
defined in Regulations section 1.6049-4(c)(1)(ii) or under  
section 6041, 6042, 6045, or 6050N). You should make this  
disclosure by attaching to Form W-8IMY the Forms W-9 (or  
substitute forms) of persons that are U.S. non-exempt  
recipients. If you do not have a Form W-9 for a non-exempt  
U.S. payee, you must attach to Form W-8IMY any  
Line 15f. Check the box on line 15f if you have assumed  
primary Form 1099 reporting and backup withholding  
responsibility with respect to the accounts identified in a  
withholding statement associated with this form or if you are  
a participating FFI or registered deemed-compliant FFI that  
meets the requirements to report only under Regulations  
sections 1.6049-4(c)(4)(i) and (c)(4)(ii). For accounts for  
which you check this box on line 15f, you should not check  
the boxes on lines 15g through 15i.  
information you do have regarding that person’s name,  
address, and TIN for a withholding agent to report the  
payment.  
Line 16a. Check the box on line 16a to certify that each  
QDD identified on the form or on the QDD withholding  
statement that is acting as a QDD meets the requirements to  
act as a QDD in Regulations section 1.1441-1(e)(6) and  
assumes primary withholding and reporting responsibilities  
under chapters 3, 4, and 61, and section 3406 with respect to  
potential section 871(m) transactions and has been  
approved by the IRS to act as a QDD.  
If you checked boxes 15a and 15f with respect to any  
accounts, or box 15b or 15c (as applicable) and the  
box on line 15f when this form is associated with an  
TIP  
amount realized or PTP distribution, you do not have to  
provide a withholding statement for any payments made to  
those accounts.  
A QDD must act as a QDD for all payments it  
Line 15g. Check the box on line 15g if you have not  
assumed primary Form 1099 reporting and backup  
withholding responsibility with respect to the account(s)  
identified on a withholding statement attached to this form  
(or, if no withholding statement is attached to this form, for all  
accounts). This box applies to an amount realized only if you  
have not checked the box on line 15b and does not apply to a  
payment made by a QSL that is described on line 15d. If you  
check the box on line 15g, check the applicable  
receives as a principal with respect to potential  
!
CAUTION  
section 871(m) transactions and underlying  
securities, excluding any payments that are treated as  
effectively connected with the conduct of a trade or business  
within the United States within the meaning of section 864. A  
QDD may not act as a QDD for any other payments it  
receives. To certify your foreign status for any other payment  
of U.S. source income you beneficially own, see Who Must  
Provide Form W-8IMY and Do Not Use Form W-8IMY If You  
are Described Below, earlier.  
certification(s) on line 15h or 15i.  
Lines 15h and 15i. If you are allocating any portion of the  
payment on a withholding statement to a chapter 4  
withholding rate pool of U.S. payees in lieu of providing  
Forms W-9, you must certify by checking the boxes on lines  
15h and/or 15i (as applicable):  
Line 16b. Check the box to indicate your status, including if  
you are a QDD that is a disregarded entity claiming treaty  
benefits. If the QDD is a branch other than a disregarded  
entity (that is, a branch that is not a separate legal entity from  
its home office), check the box to indicate the status of the  
entity identified in Part I. If the Form W-8IMY is being used for  
more than one QDD and different boxes must be checked for  
different QDDs, check all relevant boxes and include the  
applicable information on the withholding statement for each  
QDD. See QDD withholding statement, later.  
Claim of treaty benefits or beneficial ownership. If you  
are acting as a QDD, you may be entitled to claim treaty  
benefits for certain payments that are subject to withholding  
that you receive in your principal capacity (for example,  
interest payments or payments of dividends beginning in  
For each account holder included in a chapter 4  
withholding rate pool of U.S. payees who holds an account  
that you maintain, you are permitted to provide this pool  
under Regulations section 1.6049-4(c)(4)(iii) (including for  
payments of income other than interest for which reporting  
would be required under chapter 61 but for a coordination  
rule similar to that provided in Regulations section  
1.6049-4(c)(4)(iii)); and/or  
For a withholding rate pool of U.S. payees that includes  
account holders of another intermediary or flow-through  
entity, you have obtained or will obtain documentation to  
establish that the intermediary or flow-through entity is a  
-12-  
Instructions for Form W-8IMY (Rev. 10-2021)  
 
2023). See Notice 2020-2. To make a claim for treaty  
benefits in such a case, you may provide your withholding  
agent a statement associated with your Form W-8IMY that  
contains the information required in Part III of Form  
W-8BEN-E, including (if applicable) a treaty claim by a hybrid  
entity that is a disregarded entity that is identified on a QDD's  
withholding statement described in the instructions for Part II.  
Alternatively, a Form W-8BEN-E may be used for this  
purpose. An entity acting as a QDD (other than a  
specific partners receiving the payment (rather than including  
any part of the payment in any chapter 3 withholding rate  
pool) when you act as a disclosing QI for a payment of an  
amount realized or PTP distribution.  
For chapter 4 purposes. If you are a QI and you receive  
a withholdable payment, you must provide a withholding  
statement which satisfies the requirements of an FFI  
withholding statement or chapter 4 withholding statement (if  
you are not an FFI) when you do not assume primary  
withholding responsibility under chapter 3 and chapter 4 and  
Form 1099 reporting and backup withholding responsibility  
for the payment.  
If you are a QI that is an FFI you may provide an FFI  
withholding statement to allocate the payment to chapter 4  
withholding rate pools (as applicable) or other pool of payees  
permitted on an FFI withholding statement under the  
chapter 4 regulations. See Regulations section 1.1471-3(c)  
(3)(iii)(B)(2). You may also provide on the withholding  
statement a single pool of nonparticipating FFIs, a single pool  
of recalcitrant account holders of yours or of or another  
intermediary that is a participating FFI or registered  
deemed-compliant FFI, and, if you do not assume primary  
Form 1099 and backup withholding responsibility, a  
chapter 4 withholding rate pool of U.S. payees. A chapter 4  
withholding rate pool of U.S. payees may include:  
flow-through entity or disregarded entity) for a payment of  
U.S. source FDAP income may also use Form W-8IMY to  
claim status as the foreign beneficial owner of the payment  
when the entity provides its foreign TIN (when required) on  
line 9b to this form).  
If you are acting as a QDD and fiscally transparent in  
your jurisdiction of organization, do not claim treaty  
!
CAUTION  
benefits as described in these instructions. Instead,  
you must include the withholding certificates or documentary  
evidence of the owners claiming treaty benefits and provide  
an allocation on the withholding statement.  
QDD branch of a U.S. person. If you are a foreign branch  
of a U.S. person that is acting as a QDD and you receive a  
payment that otherwise would be subject to withholding  
except for the U.S. person’s status as a U.S. person, you  
may associate this Form W-8IMY with a Form W-9 from the  
U.S. person.  
If you are a reporting Model 1 FFI, an account holder that  
is not withheld on under chapter 3, chapter 4, or section 3406  
that you report as a U.S. account pursuant to the Model 1  
IGA because the account has U.S. indicia and you have not  
obtained appropriate documentation to treat the account as  
held by other than a specified U.S. person;  
Withholding statement of a QI. As a QI, you must provide  
a withholding statement to each withholding agent from  
which you receive reportable amounts or withholdable  
payments if you have not assumed primary withholding  
responsibility under chapter 3 and chapter 4 with respect to  
the payment for one or more accounts (as indicated  
otherwise on line 15a), or if you are receiving a reportable  
amount on behalf of a U.S. non-exempt recipient, you have  
not assumed primary Form 1099 reporting and backup  
withholding responsibility for the payment. You must also  
provide a withholding statement for an amount realized or a  
PTP distribution for which you have not assumed primary  
withholding responsibility. The withholding statement  
becomes an integral part of the Form W-8IMY and, therefore,  
the certification statement that you sign in Part XXIX of the  
form applies to the withholding statement as well as to the  
form. If you are a QDD, see also QDD withholding statement,  
later.  
If you are a reporting Model 2 FFI, an account holder that  
is not withheld on under chapter 3, chapter 4, or section 3406  
that you report as an account holder of a non-consenting  
U.S. account as described in the Model 2 IGA;  
If you are a non-U.S. payor (as described in Regulations  
section 1.6049-5(c)(5)) that is a participating FFI (including a  
reporting Model 2 FFI), registered deemed-compliant FFI, or  
reporting Model 1 FFI, an account holder not withheld on  
under chapter 4 or section 3406 who you report under  
chapter 4 or an applicable IGA (including the account  
holder’s TIN).  
Additionally, a chapter 4 withholding rate pool of U.S.  
payees may be provided in the above-described cases for a  
payment of an amount realized for which a withholding  
statement is provided for purposes of section 1446(f) that  
allocates some amount of the payment to a U.S. person.  
Example 5 and Example 6, later.  
An FFI withholding statement must also identify each  
intermediary or flow-through entity that is receiving a  
payment on behalf of a payee and include such entity’s  
chapter 4 status and GIIN (if applicable), excluding any  
intermediary or flow-through entity that is an account holder  
or interest holder in another QI, WP, or WT. An FFI  
withholding statement of a QI may combine withholding rate  
pool information provided by such an entity to the QI with  
withholding rate pools comprised of accounts that the QI  
maintains.  
A QI withholding statement must also:  
Designate those accounts for which you act as a QI;  
Designate those accounts for which you are assuming  
primary withholding and reporting responsibility under  
chapter 3 and chapter 4;  
If you receive an amount realized or a PTP distribution,  
designate those accounts for which you are assuming  
primary withholding and reporting responsibility for either  
such amount;  
If applicable, designate those accounts or payments for  
which you are acting as a QSL with respect to any U.S.  
source substitute dividends; and  
For any account for which you are not assuming primary  
withholding and reporting responsibility, provide information  
to allocate the payment, as applicable, to chapter 3  
If you are a QI that is not an FFI and that does not assume  
primary withholding responsibility under chapter 3 and  
chapter 4, you must provide, for a withholdable payment, a  
chapter 4 withholding statement that contains the name,  
address, TIN (if any), entity type (if applicable), and chapter 4  
status of each payee, the amount allocated to each payee, a  
withholding rate pools, chapter 4 withholding rate pools, or  
other pools of payees permitted under the chapter 4  
regulations. See Regulations section 1.1471-3(c)(3)(iii)(B)(2)  
(with respect to a chapter 4 withholding rate pool). You must,  
however, provide information to allocate the payment to the  
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Instructions for Form W-8IMY (Rev. 10-2021)  
valid withholding certificate or other documentation sufficient  
to establish the payee’s chapter 4 status. However, a  
chapter 4 withholding statement may include pooled  
information for payees that are nonparticipating FFIs that  
hold accounts that you maintain or hold accounts with an  
intermediary or flow-through entity receiving the payment  
from you. You may also provide another pool of payees as  
permitted under the chapter 4 regulations for a chapter 4  
withholding statement. See Regulations section 1.1471-3(c)  
(3)(iii)(B).  
For chapter 3 purposes. In the case of a reportable  
amount that is a withholdable payment, any portion of the  
payment for which you are acting as a QI that is not allocated  
to a chapter 4 withholding rate pool or a U.S. non-exempt  
recipient (including for backup withholding purposes) must  
be allocated to a chapter 3 withholding rate pool or pool of  
U.S. exempt recipients, if it is not required to be separately  
reported. The chapter 3 withholding rate pool may be  
established by any reasonable method agreed upon by you  
and the withholding agent. For example, you may agree to  
establish a separate account for a single chapter 3  
allocate the amounts subject to withholding on the  
distribution to each U.S. partner.  
Form 1099 reporting. If you do not assume primary Form  
1099 reporting and backup withholding responsibility, you  
must provide payee-specific information for each U.S.  
non-exempt recipient account holder (other than those U.S.  
payees included in a chapter 4 withholding rate pool of U.S.  
payees (described in Regulations section 1.6049-4(c)(4)(iii))  
or when the alternative procedure is used. The pools are  
based on valid documentation that you obtain or, if a  
payment cannot be reliably associated with valid  
documentation, the applicable presumption rules.  
Example 1. A QI that is a participating FFI receives a  
$100 payment of U.S. source dividends on an account for  
which it acts as a QI held with the withholding agent for the  
following recipients:  
$20 to NPFFI, a nonparticipating FFI that is an account  
holder of the QI;  
$10 each on behalf of two recalcitrant account holders of  
the QI ($20 total), each with U.S. indicia (as described in  
Regulations section 1.1441-7(b)(5)) associated with the  
account;  
withholding rate pool or you may agree to divide a payment  
made to a single account into portions allocable to each  
chapter 3 withholding rate pool. You must provide the  
chapter 3 withholding rate pool information that is required for  
the withholding agent to meet its withholding and reporting  
obligations. A withholding agent may request any information  
reasonably necessary to withhold and report payments  
correctly.  
For a payment of an amount realized. In the case of a  
payment of an amount realized, you must provide chapter 3  
withholding rate pool information with respect to the foreign  
transferors receiving the payment for your broker to meet its  
withholding and reporting obligations (except when you act  
as a disclosing QI). See Regulations section 1.1446(f)-4(a)  
(7)(iii). The chapter 3 withholding rate pool information you  
provide on a withholding statement may be properly adjusted  
to take into account the withholding required on a transferor  
that is a foreign partnership for which you permit a modified  
amount realized. With respect to U.S. transferors receiving  
an amount realized, and regardless of whether you act as a  
disclosing QI, you must allocate the payment to each such  
transferor to the extent of the amount that may not be  
allocated to a chapter 4 withholding rate pool of U.S. payees  
(to the extent permitted for chapter 4 purposes).  
For a PTP distribution. In the case of a PTP distribution,  
you must provide to the PTP or nominee from which you  
receive the distribution chapter 3 withholding rate pool  
information and chapter 4 withholding rate pool information  
(when permitted for chapter 4 purposes) for your foreign  
partners with respect to the amounts subject to withholding  
on the distribution (except when you act as a disclosing QI).  
For determining the amounts to include in each withholding  
rate pool, the QI must rely on the allocation of each amount  
subject to withholding on the distribution as determined by  
the PTP or nominee that pays the distribution to the QI. When  
acting as a disclosing QI for a PTP distribution, you must  
provide with respect to each partner an allocation of the  
income attributable to the distribution that is subject to  
withholding under section 1446(a) or (f) (and, for an amount  
subject to chapter 3 or 4 withholding, an allocation of such  
amount to each beneficial owner or payee). See Withholding  
statement, earlier, for the requirements of a withholding  
statement provided by an intermediary for a PTP distribution.  
Regardless of whether you act as a disclosing QI, you must  
$5 each on behalf of A and B, U.S. individual account  
holders of the QI that the QI reports as U.S. accounts  
pursuant to its chapter 4 reporting obligations as a  
participating FFI ($10 total);  
$10 on behalf of C, a U.S. exempt recipient that is not a  
specified U.S. person and is an indirect account holder of the  
QI (who beneficially owns the payment through an account  
with another participating FFI);  
$20 on behalf of D, a U.S. non-exempt recipient that is a  
specified U.S. person who is an indirect account holder of the  
QI (that beneficially owns the payment through an account  
with a certified deemed-compliant FFI described in  
Regulations section 1.1471-5(f)(2)); and  
$10 each on behalf of two nonresident alien individuals  
who are account holders of the QI, one of whom is entitled to  
a 15% rate of withholding under an applicable income tax  
treaty.  
The dividend payment is both a withholdable payment  
under chapter 4 and a reportable amount under chapter 3.  
The QI assumes primary withholding and reporting  
responsibility under chapter 3 and chapter 4 as well as  
primary Form 1099 reporting and backup withholding  
responsibility. As a result, the QI is not required to provide a  
withholding statement allocating the payment to specific  
payees or withholding rate pools. The QI will provide Form  
W-8IMY and check the boxes on lines 14, 15a, and 15f.  
Example 2. The facts are the same as Example 1,  
except QI is a non-U.S. payor under Regulations section  
1.6049-5(c)(5) and does not assume primary Form 1099 and  
backup withholding responsibility but reports the accounts of  
A and B as U.S. accounts under Regulations section  
1.1471-4(d).  
The QI must provide a withholding statement allocating  
$20 of the payment to D, $10 to C, and $10 to a chapter 4  
withholding rate pool of U.S. payees. The QI need not  
allocate any portion of the payment specifically to A or B  
because the QI is a non-U.S. payor that is permitted to  
include A and B in a chapter 4 withholding rate pool of U.S.  
payees under Regulations section 1.6049-4(c)(4)(i). For  
payments made on or after April 1, 2017, see the instructions  
for Part IV of this form for when a withholding statement  
includes an allocation of a payment of an amount subject to  
chapter 3 withholding that is made to a pool of U.S. payees.  
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Instructions for Form W-8IMY (Rev. 10-2021)  
 
The QI must also provide a Form W-9 (or alternatively, name  
and TIN) for D. A Form W-9 is not required for C. The QI will  
provide Form W-8IMY and check the boxes on lines 14, 15a,  
and 15g and 15h.  
Example 3. The facts are the same as Example 1, except  
the QI is a U.S. payor and does not assume primary Form  
1099 and backup withholding responsibility.  
Because the QI is a U.S. payor, it is not permitted, under  
Regulations section 1.6049-4(c)(4)(i) and (iii), to include A  
and B in a chapter 4 withholding rate pool of U.S. payees.  
The QI must provide a withholding statement allocating $5 of  
the payment to A, $5 of the payment to B, $10 of the payment  
to C, and $20 of the payment to D along with Forms W-9 (or  
name and TIN) for A, B, and D. The QI will provide Form  
W-8IMY and check the boxes on lines 14 and 15a.  
Example 4. The facts are the same as Example 1,  
except the QI is a non-U.S. payor that does not assume  
primary withholding and reporting responsibility under  
chapter 3 and chapter 4. The QI also does not assume  
primary Form 1099 and backup withholding responsibility.  
information specified in Regulations section 1.1446(f)-4(c)(2)  
(ii)(C) for QI to determine a modified amount realized of $10  
(one-half of the $20 is allocable to partners of F who are  
nonresident alien individuals and one-half allocable to a U.S.  
partner of F (USP)), and QI does not report F’s account as a  
U.S. account for purposes of chapter 4 reporting;  
$10 on behalf of foreign grantor trust H, an account holder  
of QI that has provided to QI the documentation from which  
QI can associate the amount realized with G, a nonresident  
alien that is the sole grantor of the trust;  
$10, on behalf of N, an account holder of the QI that is a  
nonqualified intermediary.  
As QI is not acting as a disclosing QI for this payment, QI  
may provide to its U.S. broker a withholding statement that  
allocates the amount realized to chapter 3 withholding rate  
pools, excluding amounts allocable to a U.S. partner or to a  
chapter 4 reporting pool of U.S. payees. QI must report on  
the withholding statement the payment allocated as follows:  
To a chapter 3 withholding rate pool at a 10% rate - $70  
(for the $40 allocable to A and B, $10 allocable to F’s  
nonresident alien partners; $10 allocable to G, and $10  
allocable to N);  
If the QI does not assume primary withholding and  
reporting responsibility under chapter 3 and chapter 4 as well  
as primary Form 1099 reporting and separate backup  
withholding responsibilities, the QI will provide an FFI  
withholding statement with the following pools:  
To a chapter 4 withholding rate pool of U.S. payees - $20  
(for the total amount allocable to C and D); and  
To USP, for the $10 of the $20 of amount realized by F that  
is allocable to USP.  
Nonparticipating FFI Pool — $20 (which is subject to  
The QI will complete Form W-8IMY and check the box on  
chapter 4 withholding);  
line 14. As QI does not assume primary withholding  
Recalcitrant Account Holder Pool — $20 (which is subject  
responsibility under section 1446(f) for the amount realized,  
QI must not check the box on line 15b but should check the  
boxes on lines 15g and 15h because it has not assumed  
Form 1099 reporting and backup withholding responsibility.  
QI does not account for any of the account holders of N on its  
withholding statement as withholding applies to N at the 10%  
rate on the payment regardless of the statuses of N’s  
account holders receiving the payment. See Regulations  
section 1.1446(f)-4(a)(2) for this withholding requirement.  
distribution in Part IV, later, however, for when N (as an NQI)  
would be permitted to provide to QI allocation information  
and beneficial owner withholding certificates for the account  
holders of N receiving the amount realized from the sale.  
With respect to grantor trust H, the withholding is determined  
with respect to grantor G, rather than H, as G is the transferor  
of the PTP interest. With respect to foreign partnership F, the  
withholding statement includes the $10 allocable to F’s  
foreign partners in a chapter 3 withholding rate pool at the  
10% rate as these partners did not claim any exception to  
withholding based on an income tax treaty. With respect to  
USP, QI discloses the identity of USP on the withholding  
statement because it does not assume primary Form 1099  
reporting and backup withholding responsibility and does not  
report the account of USP for purposes of QI’s chapter 4  
requirements as a participating FFI. QI must also provide the  
documentation permitted for section 1446(f) purposes to  
support USP’s non-foreign status. With respect to C and D,  
however, as QI reports their accounts under QI’s  
to chapter 4 withholding and which is aggregated in a single  
pool of recalcitrant account holders rather than each class  
described in Regulations section 1.1471-4(d)(6));  
Chapter 4 Withholding Rate Pool of U.S. Payees — $10  
(for the portion of the payment allocable to A and B);  
Chapter 3 30% Rate Pool — $10;  
Chapter 3 15% Rate Pool — $10; and  
0% Rate Pool — $10 (for the portion of the payment  
allocable to C).  
The QI will also be required to allocate $20 to a separate  
withholding rate pool for D because D is a U.S. non-exempt  
recipient who cannot be included in a chapter 4 withholding  
rate pool of U.S. payees (because D’s account is maintained  
by a certified deemed-compliant FFI). The QI will provide  
Form W-8IMY and check the boxes on lines 14, 15g, and  
15h.  
Example 5. A QI that is foreign corporation and a  
Participating FFI does not assume primary withholding and  
reporting responsibility for a payment of $100 from a U.S.  
broker that is an amount realized from the sale of a PTP  
interest. The QI also does not assume primary Form 1099  
reporting and backup withholding responsibility for any of its  
accounts. The QI holds the PTP interest in an account with a  
U.S. broker and does not act as a disclosing QI for the  
payment of the amount realized. The QI determines that the  
amount realized from the sale is allocable to the following  
transferors of the interest in the PTP on whose behalf the QI  
held the interest:  
requirements as a participating FFI, QI may report the  
amount realized allocable to C and D in a chapter 4  
$20 each on behalf of A and B, two nonresident alien  
individuals who are account holders of the QI;  
withholding rate pool of U.S. payees.  
$10 each on behalf of C and D, two U.S. individual  
Example 6. The facts are the same as Example 5, except  
the QI acts as a disclosing QI for the payment of the amount  
realized. Unlike Example 5, because the QI is a disclosing  
QI, it may not allocate any portion of the payment to a  
chapter 3 withholding rate pool on the withholding statement  
account holders of the QI that the QI reports as U.S.  
accounts pursuant to its chapter 4 reporting obligations as a  
participating FFI;  
$20 on behalf of F, a foreign partnership and account  
holder of the QI that has provided the certification and other  
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Instructions for Form W-8IMY (Rev. 10-2021)  
   
provided to the U.S. broker. QI must instead allocate the  
payment of the amount realized to each account holder that  
is a transferor of the PTP interest, excluding any transferors  
that are includible in a chapter 4 withholding rate pool of U.S.  
payees. See Regulations section 1.1446(f)-4(a)(7)(iii). Thus,  
with respect to QI’s account holders that are foreign  
The amount allocable to these two pools under the  
alternative procedure excludes amounts allocated to  
the chapter 4 withholding rate pool of U.S. payees.  
!
CAUTION  
Updating the statement. Your withholding statement must  
be updated as often as is necessary to allow the withholding  
agent to withhold at the appropriate rate on each payment  
and to correctly report the income to the IRS. The updated  
information becomes an integral part of Form W-8IMY.  
transferors, QI must allocate $20 of the amount realized each  
to A and B and must associate a valid Form W-8BEN for  
each of them with the withholding statement. With respect to  
foreign partnership F, QI must identify F as the transferor of  
the interest (with a valid Form W-8IMY from F completed in  
accordance with Part VIII , later), must indicate on its  
withholding statement that QI has determined a modified  
amount realized of $10 from the $20 of the amount realized  
allocable to F, and must allocate the amount realized  
between each of the partners of F based on the certification  
and withholding statement provided by F for this payment in  
accordance with Regulations section 1.1446(f)-4(c)(2)(ii)(C).  
QI must include on the withholding statement the amount  
allocable to USP for the reasons noted in Example 5, earlier,  
(with the documentation permitted to support USP’s  
QDD withholding statement. Similar to a QI withholding  
statement, a QDD withholding statement becomes an  
integral part of a QDD's Form W-8IMY. In addition to the  
information required on a withholding statement (if any) you  
provide in your QI capacity, generally a QDD withholding  
statement should (as applicable) for each QDD (identifying  
the QDD by name used for the QI application):  
Designate the accounts for which the QDD is receiving  
payments with respect to potential section 871(m)  
transactions or underlying securities as a QDD;  
Designate the accounts for which the QDD is receiving  
payments with respect to potential section 871(m)  
transactions as a QDD (and that are not underlying  
securities) for which withholding is not required;  
non-foreign status) that F should have provided to QI with its  
withholding statement. With respect to foreign grantor trust  
H, QI must allocate the $10 received on behalf of H to G (as  
G is the transferor), and must associate with the withholding  
statement a valid Form W-8IMY from H (completed in  
accordance with Part VIII, later), a valid Form W-8BEN from  
G, and information provided by H regarding the amount  
realized allocable to G. With respect to nonqualified  
Designate the accounts for which the QDD is receiving  
payments with respect to underlying securities as a QDD for  
which withholding is required; and  
Identify the home office or branch that is treated as the  
owner for U.S. income tax purposes.  
If you are acting as a QDD that meets the conditions  
described below, you must provide on line 9b, your foreign  
taxpayer identification number (FTIN) issued by the  
jurisdiction in which you are tax resident identified on line 6,  
unless you were not issued an FTIN (including if the  
jurisdiction does not issue FTINs). If you do not provide your  
FTIN, you must provide on your QDD withholding statement  
a reasonable explanation of why you have not been issued  
an FTIN. For this purpose, such an explanation includes a  
statement that you are not legally required to obtain an FTIN  
in your jurisdiction of tax residence. Do not write “not  
applicable.” If you are acting as a QDD, you are required to  
provide your FTIN or an explanation of why you have not  
been issued an FTIN if:  
intermediary N, QI must allocate the $10 received on behalf  
of N to N and associate this amount with the withholding  
statement and a valid Form W-8IMY from N. See Withholding  
later, however, for when N would also be permitted to provide  
to QI allocation information and beneficial owner withholding  
certificates for the account holders of N receiving the amount  
realized from the sale. As indicated in Example 5, earlier, QI  
may include C and D in a chapter 4 withholding rate pool of  
U.S. payees with respect to the amount allocable to them (an  
allowance that applies even when a QI acts as a disclosing  
QI for an amount realized).  
Alternative procedure for reportable amounts paid to  
U.S. non-exempt recipients (and for chapter 4). If  
approved by the withholding agent, you can establish:  
You are providing this Form W-8IMY to document yourself  
as an account holder (as defined in Regulations section  
1.1471-5(a)(3)) with respect to a financial account (as  
defined in Regulations section 1.1471-5(b)) that you hold at a  
U.S. office of a financial institution (including a U.S. branch of  
an FFI);  
A single pool (not subject to backup withholding) for all  
U.S. non-exempt recipient account holders for whom you  
have provided Forms W-9 or are includible in a chapter 4  
withholding rate pool of U.S. payees prior to the withholding  
agent making any payments. Alternatively, you may include  
such U.S. non-exempt recipients in a zero rate withholding  
pool that includes U.S. exempt recipients and foreign  
persons exempt from non-resident alien withholding provided  
all the conditions of the alternative procedure are met; and  
You receive U.S. source income reportable on a Form  
1042-S associated with this form; and  
This form is treated as a beneficial owner withholding  
certificate under Regulations section 1.1441-1(e)(2)(i).  
If you are a QDD using its Form W-8IMY to make a claim  
ownership, earlier, for the information required for the claim  
(including for a hybrid entity that is a disregarded entity).  
A separate pool for all U.S. non-exempt recipient account  
holders subject to backup withholding for whom you have not  
provided Forms W-9 prior to the withholding agent making  
any payments.  
If you elect the alternative procedure, you must provide  
the allocation information required by your QI withholding  
agreement to the withholding agent no later than January 15  
of the year following the year in which the payments are paid.  
Failure to provide this information may result in penalties  
under sections 6721 and 6722 and termination of your  
withholding agreement with the IRS.  
Part IV — Nonqualified Intermediary  
Line 17a. If you are providing Form W-8IMY as a  
nonqualified intermediary (NQI), you must check the box on  
line 17a. By checking this box, you are certifying to all of the  
statements on line 17a.  
Line 17b. Check the box on line 17b if you are using this  
form to transmit withholding certificates or other  
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Instructions for Form W-8IMY (Rev. 10-2021)  
 
documentation along with a withholding statement that  
satisfies the requirements of chapters 3 and 4 (including for  
purposes of section 1446(a) and including if you are  
providing pooled information for purposes of chapter 61  
under the alternative procedure for U.S. non-exempt  
recipients, or chapter 4 withholding rate pools (as applicable)  
for a withholdable payment).  
For chapter 4 purposes. If you are an NQI that is a  
participating FFI or registered deemed-compliant FFI and  
you receive a withholdable payment, you must provide a  
withholding statement which satisfies the requirements of an  
FFI withholding statement or chapter 4 withholding  
statement.  
An FFI withholding statement may allocate the payment to  
chapter 4 reporting rate pools (as appropriate), including a  
chapter 4 withholding rate pool for nonparticipating FFIs,  
recalcitrant account holders (in each class of account holders  
described in Regulations section 1.1471-4(d)(6)(i)), or other  
pool of payees permitted on an FFI withholding statement  
under the chapter 3 or 4 regulations (see Regulations  
sections 1.1471-3(c)(3)(iii)(B) and 1.1441-1(e)(3)(iv)(C)),  
and, for a participating FFI (including a reporting Model 2 FFI)  
or a registered deemed-compliant FFI (including a reporting  
Model 1 FFI), U.S. payees. However, if you are an NQI, you  
may allocate a portion of a reportable amount (regardless of  
whether the payment is a withholdable payment) to a  
chapter 4 withholding rate pool of U.S. payees when you  
satisfy the requirements to provide such a pool (including the  
requirement to certify to your status as a participating FFI  
(including a reporting Model 2 FFI) or registered  
If you are required to provide a chapter 4 status on  
line 5 and are acting as an intermediary for a  
withholdable payment, you must provide your  
TIP  
chapter 4 status on line 5 or as otherwise permitted in these  
instructions to avoid withholding at the chapter 4 rate of 30%  
being applied to any withholdable payment you receive from  
the withholding agent regardless of whether you check the  
box on line 17b (except for documentation provided with  
respect to exempt beneficial owners).  
Line 17c. Check the box on line box 17c to certify that you  
are permitted under Regulations section 1.6049-4(c)(4) to  
provide a chapter 4 withholding rate pool of U.S. payees to  
which a payment is allocated on a withholding statement  
associated with the Form W-8IMY. This checkbox does not  
apply to a PTP distribution. You may check this box with  
respect to U.S. source substitute dividends you receive as a  
QSL regardless of whether you act as an intermediary or  
principal for those amounts. See the instructions to line 8 for  
a QSL's requirement to provide a U.S. TIN.  
Line 17d. Check the box on line 17d to certify that you are  
acting as a QSL with respect to the accounts identified on  
this line or in a withholding statement associated with this  
form with respect to a payment that is a U.S. source  
substitute dividend. You may check this box with respect to  
U.S. source substitute dividends you receive as a QSL  
regardless of whether you act as an intermediary or principal  
for those amounts. See the instructions for line 8 for a QSL's  
requirement to provide a U.S. TIN.  
If you are acting on behalf of another NQI or on behalf of a  
foreign partnership or foreign trust that is not a withholding  
foreign partnership or a withholding foreign trust, you must  
attach to your Form W-8IMY the Form W-8IMY of the other  
NQI, foreign partnership, or foreign trust together with the  
withholding certificates and other documentation attached to  
that Form W-8IMY that are required for both chapter 3 and  
chapter 4 purposes.  
deemed-compliant FFI (including a reporting Model 1 FFI)).  
The withholding statement must also identify each  
intermediary or flow-through entity that is receiving a  
payment (excluding any intermediary or flow-through entity  
that is an account holder or interest holder in a QI, WP, or  
WT), each such entity’s chapter 4 status and GIIN (if  
applicable), and the chapter 4 withholding rate pools  
associated with each such entity receiving the payment.  
A chapter 4 withholding statement must contain the name,  
address, TIN (if any), entity type, chapter 4 status of each  
payee, the amount allocated to each payee, and a valid  
withholding certificate or other documentation sufficient to  
establish each payee’s chapter 4 status. However, a  
chapter 4 withholding statement may instead include pooled  
information for payees that are nonparticipating FFIs or  
another pool of payees as permitted under the chapter 4  
regulations for a chapter 4 withholding statement. The  
withholding statement must also identify each intermediary or  
flow-through entity that is receiving a payment (excluding any  
intermediary or flow-through entity that is an account holder  
or interest holder in a QI, WP, or WT), each such entity’s  
chapter 4 status and GIIN (if applicable), and the chapter 4  
withholding rate pools associated with each such entity  
receiving the payment.  
If you are an NQI receiving an amount realized from  
the transfer of a PTP interest, however, the  
!
CAUTION  
preceding paragraph and the representation made  
A payment that is subject to chapter 3 withholding or  
on line 17b applies only to the extent indicated in Withholding  
that should be subject to chapter 4 withholding  
!
CAUTION  
should not be included in a U.S. payee pool that is  
described in Regulations section 1.6049-4(c)(4)(ii). Instead,  
an allocation of a payment of an amount subject to chapter 3  
withholding to a withholding rate pool of U.S. payees must  
identify the payees as described in Regulations section  
1.1471-3(c)(3)(iii)(B)(2).  
Withholding statement of an NQI. If you are an NQI, you  
must provide a withholding statement and appropriate  
documentation to obtain reduced rates of withholding under  
chapter 3 and section 3406 for your customers receiving  
reportable amounts and to avoid certain reporting  
responsibilities. However, see the paragraph later describing  
an NQI’s withholding statement for chapter 4 purposes for  
when an NQI may provide a chapter 4 withholding rate pool  
of U.S. payees instead of documentation for those payees.  
The withholding statement must be provided prior to a  
payment and becomes an integral part of the Form W-8IMY  
and, therefore, the certification statement that you sign in  
Part XXIX of the form applies to the withholding statement as  
well as to the form.  
For chapter 3 and chapter 61 purposes. For chapter 3  
and chapter 61 purposes, in the case of a reportable amount  
that is also a withholdable payment, the withholding  
statement should allocate only the portion of the payment  
that was not allocated to a chapter 4 withholding rate pool or  
a pool described in Regulations section 1.1441-1(e)(3)(iv)(C)  
or to a payee identified on the withholding statement to whom  
withholding was applied under chapter 4. The withholding  
statement must generally include the following information.  
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Instructions for Form W-8IMY (Rev. 10-2021)  
Include the name, address, U.S. TIN (if any), chapter 4  
payment and the information for the broker to allocate the  
amount realized to each transferor; and  
status (for a foreign person receiving a withholdable  
payment), and the type of documentation (documentary  
evidence, Form W-9, or type of Form W-8) for every person  
for whom documentation has been received and state  
whether that person is a U.S. exempt recipient, a U.S.  
non-exempt recipient, or a foreign person. The statement  
must indicate whether a foreign person is a beneficial owner  
or an intermediary, flow-through entity, U.S. branch, or  
territory financial institution and the type of recipient, based  
on the recipient codes shown on Form 1042-S.  
The NQI receives from the broker paying the amount  
realized a written representation that the broker is acting as  
an agent of the PTP with respect to the statement described  
in Regulations section 1.6031(c)-1T(a) or otherwise  
designates the broker as its agent for providing the statement  
to the PTP (or the PTP's agent).  
The allowance for an NQI to provide a withholding  
statement and transferor documentation applies  
!
CAUTION  
despite that an NQI may not obtain reduced  
Allocate each payment by income type to every payee for  
withholding on an amount realized it receives from the  
transfer of a PTP interest.  
whom documentation has been provided. The type of income  
is based on the income codes reported on Form 1042-S (or,  
if applicable, the income categories for Form 1099). If a  
payee receives income through another NQI, flow-through  
entity, or U.S. branch acting as an intermediary, the  
withholding certificate must also state the name, address,  
U.S. TIN (if known), and, for a withholdable payment, the  
chapter 4 status (if required) and GIIN (if applicable) of the  
other NQI or U.S. branch from which the payee directly  
receives the payment or the flow-through entity in which the  
payee has a direct ownership interest. If another NQI,  
flow-through entity, or U.S. branch fails to allocate a  
payment, you must provide, for that payment, the name of  
the NQI, flow-through entity, or U.S. branch that failed to  
allocate the payment.  
Alternative procedure for NQIs receiving reportable  
amounts (and for chapter 4). To use the alternative  
procedure you must inform the withholding agent on your  
withholding statement that you are using the procedure, and  
the withholding agent must agree to the procedure.  
Under this procedure, you must provide a withholding  
agent with all the information required on the withholding  
statement and all payee documentation, except the specific  
allocation information for each payee, prior to the payment of  
a reportable amount. In addition, you must provide the  
withholding agent with withholding rate pool information. The  
withholding statement must assign each payee that is not  
subject to withholding under chapter 4 to a chapter 3  
If a payee is identified as a foreign person, specify the rate  
withholding rate pool prior to the payment of a reportable  
amount. The withholding rate pool may be established by any  
reasonable method agreed upon by you and the withholding  
agent. For example, you may agree to establish a separate  
account for a single withholding rate pool, or you may agree  
to divide a payment made to a single account into portions  
allocable to each withholding rate pool. You must determine  
withholding rate pools based on valid documentation or, to  
the extent a payment cannot be reliably associated with valid  
documentation, the applicable presumption rules.  
You must provide the withholding agent with sufficient  
information to allocate the income in each withholding rate  
pool to each payee (including U.S. exempt recipients) within  
the pool no later than January 31 of the year following the  
year of payment. If you fail to provide allocation information, if  
required, by January 31 for any withholding rate pool, you  
may not use this procedure for any payment made after that  
date for all withholding rate pools. You may remedy your  
failure to provide allocation information by providing the  
information to the withholding agent no later than February  
14.  
of withholding under chapter 3 to which the payee is subject,  
the payee’s country of residence and, if a reduced rate of  
withholding is claimed, the basis for that reduced rate (for  
example, treaty benefit, portfolio interest, or exemption under  
section 501(c)(3), 892, or 895). The statement must also  
include the U.S. or foreign TIN (if required) and, if the  
beneficial owner is not an individual and is claiming treaty  
benefits, state whether the limitation on benefits and section  
894 statements have been provided by the beneficial owner.  
You must inform the withholding agent as to which payments  
those statements relate.  
Include any other information the withholding agent  
requests in order to fulfill its withholding and reporting  
obligations under chapters 3 and 4 of the Code and/or Form  
1099 reporting and backup withholding responsibility.  
Withholding statement for amount realized or PTP  
distribution. In the case of a PTP distribution, an NQI may  
provide a withholding statement and appropriate  
documentation for each of its account holders receiving the  
distribution to allocate to its account holders the amounts  
subject to withholding on the distribution under chapters 3  
and 4 (or under section 1446(a)). See Withholding statement,  
earlier, for additional requirements of a withholding statement  
provided by an intermediary for a PTP distribution.  
In the case of a reportable amount that is also a  
withholdable payment, you may include amounts allocable to  
a chapter 4 withholding rate pool (other than a chapter 4  
withholding rate pool of U.S. payees) and payees subject to  
chapter 4 withholding for whom you will provide  
In the case of an amount realized (including on a PTP  
distribution), however, an NQI may provide a withholding  
statement and appropriate documentation on the transferors  
of the PTP interest only when:  
payee-specific information in a 30-percent rate pool together  
with payees subject to chapter 3 withholding at the  
30-percent rate and may not otherwise apply these  
provisions for payments made to U.S. non-exempt recipients  
(regardless of whether the payment is a withholdable  
payment). For the amount of the payment allocable to a  
chapter 4 withholding rate pool of U.S. payees, you may  
include such an amount in the withholding rate pool that is  
exempt from withholding (you can include such payees in an  
exempt pool regardless of whether the payment is a  
withholdable payment). You must identify prior to the  
payment each chapter 4 withholding rate pool to be allocated  
The broker paying the amount realized to the NQI agrees  
to report (or ensures another broker will report) under section  
1461 (and, if required, under section 6045) with respect to  
the amount realized allocated each of the account holders  
that are the transferors of the PTP interest (and provide NQI  
a copy of each Form 1042-S issued due to this reporting);  
The NQI provides to the broker the statement described in  
Regulations section 1.6031(c)-1T(a)(1) with respect to each  
NQI account holder that is a partner required to be issued a  
statement under section 6031(b) for the calendar year of the  
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Instructions for Form W-8IMY (Rev. 10-2021)  
 
a portion of the payment and must also allocate by January  
31 the portion of the payment to each such pool in addition to  
allocating the payment to each other payee as described in  
the preceding paragraph. See Regulations section  
1.1441-1(e)(3)(iv)(D) for further information on alternative  
procedures for an NQI.  
documentation for persons for whom you are receiving a  
payment (as required for chapter 3, chapter 61, and section  
3406 purposes, and, in the case of a withholdable payment,  
for chapter 4 withholding and reporting purposes). You must  
also certify that you have provided or will provide a  
withholding statement (as required) with the information  
required on an NQI withholding statement.  
Alternative withholding statement. If a withholding  
agent agrees, instead of providing a withholding statement  
that contains all of the information described previously, you  
may provide an alternative withholding statement for a  
payment of a reportable amount. You may only use an  
alternative withholding statement if you are providing the  
withholding agent with withholding certificates (and not  
documentary evidence) from the beneficial owners of the  
payment. The alternative withholding statement is not  
required to include information that is already on the  
withholding certificates (including name, address, TIN,  
chapter 4 status, and GIIN), and you are not required to  
provide the rate of withholding applicable to each beneficial  
owner, so long as the withholding agent can determine the  
appropriate rate based on the withholding certificates. Just  
as for a nonqualified intermediary withholding statement, the  
alternative withholding statement must provide information  
for allocating the payment to each payee and must include  
any other information the withholding agent needs to fulfill its  
withholding and reporting obligations.  
Line 17e. As part of providing any alternative withholding  
statements that are associated with your Form W-8IMY, you  
may make the representation indicated on line 17e. If you  
check the box line 17e, you are not required to represent on  
each alternative withholding statement that the information  
on the withholding certificates provided with the alternative  
withholding statement is not inconsistent with any other  
account information you have for the beneficial owners for  
determining the appropriate rate of withholding. See  
Regulations section 1.1441-1(e)(3)(iv)(C)(3) for further  
information on the representation otherwise required on each  
alternative withholding statement.  
If this form is being provided for purposes of the entity’s  
holding of an interest in a PTP, check the box on line 18d to  
certify that you have agreed to be treated as a U.S. person  
under Regulations section 1.1446(f)-4(a)(2)(i)(B) with respect  
to an amount realized from a sale of a PTP interest. You may  
provide a withholding statement when you do not act as a  
U.S. person for an amount realized under the same  
conditions that apply to an NQI receiving an amount realized.  
distribution in Part IV, earlier. Check the box on line 18e to  
certify that you have agreed to be treated as a U.S. person  
(as described in Regulations section 1.1441-1(b)(2)(iv)) and  
as a nominee under Regulations section 1.1446-4(b)(3) with  
respect to distributions made by PTPs. If you check either the  
box on line 18d or 18e, you must provide an EIN on line 8. If  
you receive PTP distributions for which you do not act as a  
nominee under Regulations section 1.1446-4(b)(3), check  
the box on line 18f instead of the box on line 18e. You should  
provide a withholding statement to allocate the amounts  
subject to withholding on a distribution and provide the  
appropriate account holder documentation, taking into  
account the limitation on an NQI providing this  
documentation for an amount realized (to the extent  
applicable). See Withholding statement, earlier, for the  
requirements of a withholding statement provided by an  
intermediary for a PTP distribution.  
A territory entity that is a flow-through entity but is not  
a territory financial institution may not complete this  
!
CAUTION  
Part V to agree to be treated as a U.S. person.  
Instead, complete Part IV or Part VIII, as appropriate.  
Part V — Territory Financial  
Institution  
Line 18. Check the box on line 18a to certify that you are a  
financial institution (other than an investment entity that is not  
also a depository institution, custodial institution, or specified  
insurance company) incorporated or organized under the  
laws of a territory of the United States.  
Part VI — Certain U.S. Branches  
Line 19. Check the box on line 19a to certify that you are a  
U.S. branch receiving payments of income that are  
reportable amounts or withholdable payments not effectively  
connected with the conduct of a trade or business in the  
United States, payments of PTP distributions, or payments of  
amounts realized.  
You must also check either the box on line 19b or 19c if  
you are receiving payments of reportable amounts or  
withholdable payments associated with this form. Check the  
box on line 19b to certify that you are a U.S. branch of a  
foreign bank or insurance company described in this  
certification that has agreed with the withholding agent to be  
treated as a U.S. person under Regulations section  
1.1441-1(b)(2)(iv) with respect to such payments associated  
with this Form W-8IMY. In such case, you will be responsible  
for chapter 3 withholding and reporting and chapter 4  
withholding and reporting for any such payments you make  
to persons for whom you are receiving a withholdable  
payment (including any of your branches treated as NPFFIs).  
In addition, you will be treated as a U.S. payor for chapter 61  
purposes by checking the box on line 19b (including for  
backup withholding under section 3406). You must provide  
your EIN on line 8. You do not need to provide a chapter 4  
status on line 5 or a GIIN on line 9.  
You must also check either the box on line 18b or 18c, the  
box on line 18d, and either the box line on 18e or 18f (each  
box as applicable based on the types of payments received).  
Check the box on line 18b to certify that you have agreed to  
be treated as a U.S. person for purposes of both chapter 3  
and chapter 4 with respect to payments of reportable  
amounts and withholdable payments associated with this  
Form W-8IMY. In this case, you will be responsible for  
chapter 3 withholding and reporting, backup withholding  
under section 3406, and chapter 4 withholding and reporting  
for any payments you make to persons for whom you are  
receiving a reportable amount or withholdable payment. If  
you check the box on line 18b, you must provide an EIN on  
line 8.  
Check the box on line 18c to certify that you are a territory  
financial institution that has not agreed to be treated as a  
U.S. person for reportable amounts and withholdable  
payments associated with this form. You must certify that you  
are transmitting withholding certificates or other  
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Instructions for Form W-8IMY (Rev. 10-2021)  
 
Check the box on line 19c to certify that you are a U.S.  
branch that does not have an agreement with the withholding  
agent to be treated as a U.S. person under Regulations  
section 1.1441-1(b)(2)(iv). You must certify that you are  
transmitting withholding certificates or other documentation  
for persons for whom you are receiving the payment of a  
reportable amount or withholdable payment. You must also  
certify that you have provided or will provide a withholding  
statement (as required) with the information required on an  
NQI withholding statement. Also, check the box on line 19c to  
certify that, when you are receiving a withholdable payment  
associated with this form, you are applying the rules  
described in Regulations section 1.1471-4(d)(2)(iii)(C). You  
must also provide your EIN on line 8 but do not need to  
include a chapter 4 status in Part I, line 5, or a GIIN on line 9.  
If you are unable to make this certification, you cannot fill out  
this part but instead must check the box on line 5 indicating  
you are a nonparticipating FFI.  
or any other amount subject to withholding on a PTP  
distribution. If you are also receiving payments from the same  
withholding agent for persons other than your partners,  
beneficiaries, or owners, you must provide a separate Form  
W-8IMY for those payments. If you are receiving a  
withholdable payment, you must provide your chapter 4  
status on line 5 and provide your GIIN (if applicable).  
Part VIII — Nonwithholding Foreign  
Partnership, Simple Trust, or Grantor  
Trust  
Line 21a. Check the box on line 21a if you are a foreign  
partnership or a foreign simple or grantor trust that is not a  
WP or WT, and is providing this form for payments that are  
not effectively connected, or are not treated as effectively  
connected, with the conduct of a trade or business in the  
United States.  
If this form is being provided for purposes of the entity’s  
holding of an interest in a PTP, check the box on line 19d to  
certify that you are a U.S. branch described in Regulations  
section 1.1446(f)-4(a)(2)(i)(B) that is acting as a U.S. person  
with respect to an amount realized from the sale of a PTP  
interest. You may provide a withholding statement when you  
do not act as a U.S. person for an amount realized under the  
same conditions that apply to an NQI receiving an amount  
PTP distribution in Part IV, earlier. Check the box on line 19e  
to certify that you are a U.S. branch described in Regulations  
section 1.1441-1(b)(2)(iv) that is acting as a nominee with  
respect to distributions by PTPs under Regulations section  
1.1446-4(b)(3). You must provide your EIN on line 8 but do  
not need to provide a chapter 4 status on line 5 or a GIIN on  
line 9 when you check either the box on line 19d or 19e. If  
you are a U.S. branch receiving PTP distributions associated  
with the form and are not acting as a nominee for the  
distributions under Regulations section 1.1446-4(b)(3), you  
should check the box on line 19f instead of the box on  
line 19e. You should provide a withholding statement to  
allocate the amounts subject to withholding on a distribution  
and provide the appropriate account holder documentation,  
taking into account the limitation on an NQI providing this  
documentation for an amount realized (to the extent  
Line 21b. Check the box on line 21b if you are a foreign  
partnership or foreign grantor trust providing this form for  
purposes of section 1446(a). See Foreign partnerships and  
1446(a), later. If you are a foreign partnership (other than a  
WP) or grantor trust receiving payments of both the amounts  
described on line 21a and for purposes of section 1446(a),  
you should check both boxes. By checking either box, you  
are certifying to the applicable statements on the form.  
Note. If you are receiving income that is effectively  
connected with the conduct of a trade or business in the  
United States, provide Form W-8ECI (instead of Form  
W-8IMY), when you are permitted to use that form to claim an  
exemption from withholding. If you are not receiving the  
income on behalf of your partners, beneficiaries, or owners,  
do not complete Part VIII. If you are a hybrid entity claiming  
treaty benefits, provide Form W-8BEN-E. However, if you are  
receiving a withholdable payment you may also be required  
to provide this Form W-8IMY and provide your chapter 4  
status and the chapter 4 status of each of your owners. See  
the Instructions for Form W-8BEN-E for more information  
about hybrid entities claiming treaty benefits.  
If you are receiving a withholdable payment, you must  
provide a chapter 4 status on line 5 and provide your GIIN (if  
applicable) and the information required for the withholding  
agent to report under section 1472 (to the extent required).  
applicable). See Withholding statement, earlier, for the  
requirements of a withholding statement provided by an  
intermediary for a PTP distribution.  
Withholding statement of nonwithholding foreign part-  
nership or nonwithholding foreign trust for purposes of  
chapters 3 and 4. You must provide the withholding agent  
with a withholding statement to obtain reduced rates of  
withholding and relief from certain reporting obligations. The  
withholding statement must provide the same information as  
required for an NQI withholding statement, including the  
information required with respect to an NQI, foreign  
Part VII — Withholding Foreign  
Partnership (WP) or Withholding  
Foreign Trust (WT)  
Line 20. Check the box on line 20 if you are a WP or a WT  
and you are receiving the payment on behalf of your  
partners, beneficiaries, or owners.  
partnership, or foreign trust (other than a WP or WT) for  
which you receive a payment. The withholding statement  
becomes an integral part of the Form W-8IMY. If you are an  
FFI and allocate any portion of the payment to a chapter 4  
withholding rate pool of U.S. payees with respect to accounts  
that you maintain, you must meet the requirements of  
Regulations section 1.6049-4(c)(4)(iii) and certify to your  
status in Part I, line 5, as a participating FFI, registered  
deemed-compliant FFI, reporting Model 1 FFI, or reporting  
Model 2 FFI. By providing a withholding statement making  
such an allocation with this form, you certify that you meet the  
If you are acting as a WP or WT, you must assume  
primary withholding and reporting responsibility under  
chapter 3 and chapter 4 for all payments that are made to  
you for your partners, beneficiaries, or owners. Therefore,  
you are not required to provide information to the withholding  
agent regarding each partner’s, beneficiary’s, or owner’s  
distributive share of the payment and the information for the  
withholding agent to report under section 1472 (if otherwise  
required). You are not, however, permitted to assume  
primary withholding and reporting responsibility for payments  
subject to withholding under section 1445, 1446(a), 1446(f),  
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Instructions for Form W-8IMY (Rev. 10-2021)  
 
requirements outlined for an NQI withholding statement  
described earlier.  
If you are providing this Form W-8IMY solely for  
purposes of section 1446(a) or (f), you are not  
required to provide a chapter 4 status because items  
TIP  
Foreign partnerships and trusts providing Form W-8IMY  
for purposes of section 1446(a). In general, a partnership  
is required to withhold under section 1446(a) on effectively  
connected taxable income (ECTI) allocable to a foreign  
partner (or in the case of a PTP distribution, to the extent the  
distribution is attributable to ECTI, unless withholding is  
required by a nominee). A foreign upper-tier partnership  
(UTP) that is a partner in a lower-tier partnership (LTP)  
should provide the LTP with a Form W-8IMY and, for a  
partnership other than a PTP, documentation sufficient for  
the LTP (or nominee for the amounts) to determine the status  
of the indirect partner to whom the ECTI is allocable (looking  
through additional foreign UTPs, if applicable) and to  
determine such partner’s share of the lower-tier partnership’s  
ECTI.  
Also, for purposes of section 1446(a), a foreign grantor  
trust that is a partner in a partnership should provide Form  
W-8IMY to the partnership along with documentation and  
information concerning the grantor or other owner sufficient  
for the partnership to reliably associate the portion of the  
trust’s allocable share of ECTI with the grantor or other  
owner.  
of effectively connected income are not withholdable  
payments. However, if you do not provide a chapter 4 status  
and subsequently receive a withholdable payment, you will  
also be required to provide a Form W-8IMY to provide your  
chapter 4 status or the lower-tier partnership or broker  
making the payment to you may have to withhold on the  
payment. You may provide your chapter 4 status on this form  
even if you are not required to do so.  
Line 21f. To the extent that the entity identified in Part 1 of  
this form is providing an alternative withholding statement  
described in Regulations section 1.1441-1(e)(3)(iv)(C)(3),  
you may check the box on this line to make the  
representation included on this line instead of making the  
representation on each alternative withholding statement.  
Certification of Chapter 4 Status:  
Parts IX Through XXVIII  
You should complete only one part certifying to your  
chapter 4 status (if required). Identify which part (if any) you  
should complete by reference to the box you checked on  
line 5.  
Check the box on line 21b to certify that you are a foreign  
partnership or grantor trust providing this Form W-8IMY to a  
lower-tier partnership for purposes of section 1446(a).  
Lines 21c and 21d. Check the box on line 21c if you are a  
foreign partnership that is a transferor of an interest in a  
partnership receiving an amount realized from the transfer. If  
you check the box on line 21c and are providing a  
Part IX — Nonparticipating FFI With  
Exempt Beneficial Owners  
You are not required to complete this part unless you  
are a nonparticipating FFI providing documentation  
on behalf of an exempt beneficial owner.  
TIP  
withholding statement for a modified amount realized on the  
transfer, also check the box on line 21d. The withholding  
statement for a modified amount realized must show the  
allocation of the gain from the transfer to each of the partners  
for which a lower rate of withholding is being requested, and  
you must provide withholding certificates for each of the  
partners to avoid the requirement that the transferee (or your  
broker for a transfer of a PTP interest) treat a partner as a  
presumed foreign partner.  
Line 22. Check the box on line 22 to certify that you are  
transmitting withholding certificates or other documentation  
for exempt beneficial owners for chapter 4 purposes on  
whose behalf you are receiving a payment that is a  
withholdable payment. See Regulations section 1.1471-6.  
You must also certify that you have provided or will provide a  
withholding statement (as required) allocating a portion of the  
payment to the exempt beneficial owners as required under  
Regulations section 1.1471-3(d)(8)(ii). The withholding  
statement must include the name, address, TIN (if any),  
entity type, and chapter 4 status of each exempt beneficial  
owner on behalf of which you are receiving the payment, the  
amount of the payment allocable to each exempt beneficial  
owner, a valid withholding certificate or other documentation  
sufficient to establish the chapter 4 status of each exempt  
beneficial owner under the requirements of chapter 4, and  
any other information the withholding agent reasonably  
requests in order to fulfill its obligations under chapter 4.  
Additionally, the withholding statement must provide all  
information required for purposes of chapter 3 with respect to  
each exempt beneficial owner if the payment is an amount  
subject to chapter 3 withholding. The withholding statement  
must allocate the remainder of the payment that is not  
allocated to an exempt beneficial owner to you.  
For a modified amount realized, you may not use a  
withholding statement that you provided to your  
!
CAUTION  
transferee or broker that only allocates a reportable  
amount or withholdable payment to your partners. You must  
provide a withholding statement that allocates the gain from  
the transfer of the PTP interest. Once you have provided that  
withholding statement, you may provide it for a subsequent  
amount realized provided that the gain allocations have not  
changed. You may instead provide a withholding statement  
that indicates both that it may be used for all reportable  
amounts, withholdable payments and gains on transfers  
allocable to your partners and that you will update the  
withholding statement for a change to any of these  
allocations.  
Line 21e. Check the box on line 21e if you are a foreign  
grantor trust providing the form on behalf of each grantor or  
owner of the trust under Regulations section 1.1446(f)-1(c)(2)  
(vii) that is transmitting withholding certificates and providing  
a withholding statement to allocate an amount realized to  
each grantor or other owner in the trust for purposes of  
section 1446(f).  
Part X — Sponsored FFI  
Line 23a. If you are a sponsored FFI described in  
Regulations section 1.1471-5(f)(1)(i)(F), on line 23a, enter  
the name of the sponsoring entity that has agreed to fulfill  
your chapter 4 due diligence, reporting, and withholding  
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Instructions for Form W-8IMY (Rev. 10-2021)  
   
obligations on your behalf. You must provide your GIIN on  
line 9.  
Lines 23b and 23c. You must check the applicable box on  
line 23b or 23c to certify that you are either an investment  
entity or controlled foreign corporation (within the meaning of  
section 957(a)) and satisfy the other relevant requirements  
for this classification.  
Part XV — Certified  
Deemed-Compliant Limited Life Debt  
Investment Entity  
Line 28. You must check the box on line 28 to certify that  
you satisfy the requirements for certified deemed-compliant  
limited life debt investment entity status.  
Part XI — Owner-Documented FFI  
Part XVI — Certain Investment  
Entities that Do Not Maintain  
Financial Accounts  
Line 29. You must check the box on line 29 to certify that  
you meet all of the requirements for certified  
deemed-compliant status as an investment entity that does  
not maintain financial accounts.  
An owner-documented FFI should only complete  
Form W-8IMY if it is a flow-through entity receiving  
!
CAUTION  
income allocable to its partners, owners, or  
beneficiaries. An owner-documented FFI is not permitted to  
act as an intermediary with respect to a withholdable  
payment.  
Line 24a. You must check the box on line 24a to certify that  
you satisfy the requirements for owner-documented FFI  
status and are providing this form to a U.S. financial  
institution, a participating FFI, or a reporting Model 1 FFI that  
has agreed to act as a designated withholding agent with  
respect to you (see Regulations section 1.1471-5(f)(3)).  
Lines 24b and 24c. You must also check either the box on  
line 24b or 24c. Check the box on line 24b to certify that you  
have provided or will provide the documentation set forth in  
the certifications, including the owner reporting statement  
described on this line 24b. Check the box on line 24c to  
certify that you have provided or will provide an auditor’s  
letter (in lieu of the information required by line 24b) that  
satisfies the requirements described on this line.  
Part XVII — Restricted Distributor  
Line 30a. You must check the box on line 30a to certify that  
you satisfy the requirements of restricted distributor status.  
Lines 30b and 30c. You must also check either the box on  
line 30b or 30c, as appropriate, to certify that your distribution  
agreement meets the requirements of this classification.  
Part XVIII — Foreign Central Bank of  
Issue  
Line 31. You must check the box on line 31 to certify that  
you are a foreign central bank of issue acting as an  
intermediary and are an entity defined in Regulations section  
1.1471-6 that is treated as the beneficial owner of the  
payment for chapter 4 purposes (applying the rule in  
Regulations section 1.1471-6(d)(4)). You cannot be treated  
as an intermediary for purposes of this Part XVIII if you are  
receiving the payment in connection with a commercial  
activity described in Regulations section 1.1471-6(h)(1) or  
are not receiving payments subject to chapter 3 withholding.  
Part XII — Certified  
Deemed-Compliant Nonregistering  
Local Bank  
Line 25. You must check the box on line 25 to certify that  
you satisfy all of the requirements for certified  
deemed-compliant nonregistering local bank status.  
Part XIX — Nonreporting IGA FFI  
Part XIII — Certified  
Line 32. Check the box on line 32 to indicate that you are  
treated as a nonreporting IGA FFI. You must identify the IGA  
by entering the name of the jurisdiction that has the  
Deemed-Compliant FFI with Only  
Low-Value Accounts  
applicable IGA in effect with the United States and indicate  
whether it is a Model 1 or a Model 2 IGA. You must also  
provide the withholding agent with the specific category of  
entity described in Annex II of the IGA applicable to your  
status. In providing the specific category of FFI described in  
Annex II, you should use the language from Annex II that best  
and most specifically describes your status in the IGA. For  
example, indicate “investment entity wholly owned by exempt  
beneficial owners” rather than “exempt beneficial owner.” If  
you are a nonreporting IGA FFI claiming a deemed-compliant  
status under the regulations, you must instead indicate on  
this line which section of the regulations you qualify under.  
Line 26. You must check the box on line 26 to certify that  
you satisfy all of the requirements for certified  
deemed-compliant FFI with only low-value account status.  
Part XIV — Certified  
Deemed-Compliant Sponsored,  
Closely Held Investment Vehicle  
Line 27a. On line 27a, enter the name of the sponsoring  
entity that has agreed to fulfill your chapter 4 due diligence,  
reporting, and withholding obligations on your behalf. You  
must also enter the GIIN of your sponsoring entity on line 9.  
Line 27b. You must check the box on line 27b to certify that  
you satisfy the requirements for certified deemed-compliant  
classification as a sponsored closely held investment vehicle.  
If you are a nonreporting financial institution under an  
applicable IGA because you qualify as an  
owner-documented FFI under the regulations, do not check  
“Nonreporting IGA FFI.” Instead you must check  
“Owner-documented FFI” and complete Part XI rather than  
this Part XIX.  
See instructions for line 9 for when a GIIN is required for a  
nonreporting IGA FFI (including a trustee of a  
trustee-documented trust that is a foreign person).  
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Instructions for Form W-8IMY (Rev. 10-2021)  
status. See Regulations section 1.1472-1(c)(1)(iii) for the  
definition of an excepted territory NFFE.  
Part XX — Exempt Retirement Plans  
Line 33. You must check the appropriate box on line 33a, b,  
c, d, e, or f to certify that you satisfy the requirements of  
exempt retirement plan status.  
Part XXVI — Active NFFE  
Line 39. You must check the box on line 39 to certify that  
you satisfy the requirements of active NFFE status.  
If you are not a flow-through entity or acting as an  
intermediary with respect to the payment for  
!
Part XXVII — Passive NFFE  
CAUTION  
chapter 3 purposes, do not complete Form W-8IMY.  
If you are the beneficial owner of the payment and are  
claiming an exemption under sections 115(2), 892, or 895 as  
well as exempt beneficial owner status under Regulations  
section 1.1471-6 you should provide Form W-8EXP. If you  
are receiving payments which do not qualify for a statutory  
exemption from tax but for which you are claiming benefits  
under an applicable income tax treaty, provide Form  
W-8BEN-E.  
Line 40. If you are a passive NFFE, you must check the box  
on line 40 to certify that you are not a financial institution  
(other than an investment entity organized in a possession of  
the United States). You must also certify that you have  
provided a withholding statement associated with Form  
W-8IMY to the extent you are required to provide a  
withholding statement.  
Note. If you would be a passive NFFE but for the fact that  
you are managed by certain types of financial institutions  
(see Regulations section 1.1471-5(e)(4)(i)(B)), you should  
not complete Part XXVII as you would be considered a  
financial institution and not a passive NFFE.  
Part XXI — Excepted Nonfinancial  
Group Entity  
Line 34. You must check the box on line 34 to certify that  
you satisfy the requirements of excepted nonfinancial group  
entity status.  
Part XXVIII— Sponsored Direct  
Reporting NFFE  
Lines 41 and 42. If you are a sponsored direct reporting  
NFFE, you must check the box on line 42 to certify that you  
are not a financial institution and that you satisfy all relevant  
requirements for this classification. Enter the name of the  
sponsoring entity on line 41.  
Part XXII — Excepted Nonfinancial  
Start-Up Company  
Line 35. You must check the box on line 35 to certify that  
you satisfy the requirements of excepted nonfinancial  
start-up company status. You must also provide the date you  
were formed or your board passed a resolution (or equivalent  
measure) approving a new line of business (which cannot be  
that of a financial institution or passive NFFE).  
Part XXIX — Certification  
Form W-8IMY must be signed and dated by a person  
authorized to sign a declaration under penalties of perjury on  
behalf of the person whose name is on the form. By signing  
Form W-8IMY the authorized representative, officer, or agent  
also agrees to provide a new form within 30 days following a  
change in circumstances (unless no future payments will be  
made to the intermediary or flow-through entity by the  
withholding agent and the requestor does not need an  
updated form for chapter 4 purposes).  
Part XXIII — Excepted Nonfinancial  
Entity in Liquidation or Bankruptcy  
Line 36. You must check the box on line 36 to certify that  
you satisfy the requirements of excepted nonfinancial entity  
in liquidation or bankruptcy status. You must also provide the  
date that you filed a plan of liquidation, plan of reorganization,  
or bankruptcy petition.  
A withholding agent may allow you to provide this form  
with an electronic signature. The electronic signature must  
indicate that the form was electronically signed by a person  
authorized to do so (for example, with a time and date stamp  
and a statement that the form has been electronically  
signed). Simply typing your name into the signature line is not  
an electronic signature. A withholding agent may also rely on  
an electronically signed withholding certificate if you provide  
any additional information or documentation requested by  
the withholding agent to support that the form was signed by  
you or other person authorized to do so. See Regulations  
section 1.1441-1(e)(4)(i)(B).  
Part XXIV — Publicly Traded NFFE or  
NFFE Affiliate of a Publicly Traded  
Corporation  
Lines 37a and 37b. If you are a publicly traded NFFE, you  
must check the box on line 37a to certify that you are not a  
financial institution and provide the name of a securities  
exchange on which your stock is publicly traded. If you are an  
NFFE that is a member of the same expanded affiliated  
group (as described in Regulations section 1.1471-5(i)) as a  
publicly traded U.S. or foreign entity, you must check the box  
on line 37b to certify that you are an NFFE affiliate of a  
publicly traded corporation, provide the name of the publicly  
traded entity, and identify the securities market on which the  
stock of the publicly traded entity is traded. See Regulations  
section 1.1472-1(c)(1)(i) to determine if an entity is publicly  
traded.  
Special Instructions  
Entities Providing Certifications Under an  
Applicable IGA (Do Not Complete Line 5)  
An FFI in an IGA jurisdiction with which you have an account  
may provide you with a chapter 4 status certification other  
than as shown in Parts IX through XXVIII in order to satisfy its  
due diligence requirements under the applicable IGA. In such  
a case, you may attach the alternative certification to this  
Form W-8IMY in lieu of completing a certification otherwise  
required in Parts IX through XXVIII provided that you (a)  
Part XXV — Excepted Territory NFFE  
Line 38. You must check the box on line 38 to certify that  
you satisfy the requirements for excepted territory NFFE  
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Instructions for Form W-8IMY (Rev. 10-2021)  
 
determine that the certification accurately reflects your status  
for chapter 4 purposes or under an applicable IGA; and (b)  
the withholding agent provides a written statement to you that  
it has provided the certification to meet its due diligence  
requirements as a participating FFI or registered  
(if, for example, new regulations provide for an additional  
status and this form has not been updated) then you may  
provide an attachment certifying that you qualify for the  
applicable status described in a particular Regulations  
section. Include a citation to the applicable provision in the  
Regulations. Any such attached certification becomes an  
integral part of this Form W-8IMY and is subject to the  
penalties of perjury statement and other certifications made  
in Part XXIX.  
deemed-compliant FFI under an applicable IGA. For  
example, Entity A organized in Country A holds an account  
with an FFI in Country B. Country B has a Model 1 IGA in  
effect. The FFI in Country B may ask Entity A to provide a  
chapter 4 status certification based on the terms of the  
Country B IGA in order to fulfill its due diligence and  
documentation requirements under the Country B IGA.  
Paperwork Reduction Act Notice. We ask for the  
information on this form to carry out the Internal Revenue  
laws of the United States. You are required to provide the  
information. We need it to ensure that you are complying with  
these laws and to allow us to figure and collect the right  
amount of tax.  
You may also provide with this form an applicable IGA  
certification if you are determining your chapter 4 status  
under the definitions provided in an applicable IGA and your  
certification identifies the jurisdiction that is treated as having  
an IGA in effect and describes your status as an NFFE or FFI  
in accordance with the applicable IGA. However, if you  
determine your status under an applicable IGA as an NFFE,  
you must still determine if you are an excepted NFFE under  
the regulations in order to complete this form unless you are  
provided an alternative certification by an FFI described in  
the preceding paragraph that covers your certification as an  
NFFE (such as “active NFFE”) as defined in an applicable  
IGA. Additionally, you are required to comply with the  
conditions of your status under the law of the IGA jurisdiction  
if you are determining your status under that IGA. If you  
cannot provide the certifications in Parts IX through XXVIII,  
do not check a box on line 5. However, if you determine your  
status under the definitions of the IGA and can certify to a  
chapter 4 status included on this form, you do not need to  
provide the certifications described in this paragraph unless  
required by the FFI to whom you are providing this form.  
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 this form will vary  
depending on individual circumstances. The estimated  
burden for business taxpayers filing this form is approved  
under OMB control number 1545-0123. The estimated  
burden for all other taxpayers who file this form is shown  
below. The estimated average time is: Recordkeeping,15  
hrs., 04 mins.; Learning about the law or the form, 6 hrs.,  
31 mins.; Preparing the form, 8 hrs.; Sending 16 mins.  
Any certifications provided under an applicable IGA  
remain subject to the penalties of perjury statement and other  
certifications made in Part XXIX.  
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 send us  
comments from IRS.gov/FormComments. You can write to  
the Internal Revenue Service, Tax Forms and Publications,  
1111 Constitution Ave. NW, IR-6526, Washington, DC  
20224. Do not send Form W-8IMY to this office. Instead, give  
it to your withholding agent.  
Entities Providing Alternate or Additional  
Certifications Under Regulations  
If you qualify for a status that is not shown on of this form, you  
may attach applicable certifications for such status from any  
other Form W-8 on which the relevant certifications appear. If  
the applicable certifications do not appear on any Form W-8  
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Instructions for Form W-8IMY (Rev. 10-2021)