Instructions for Form W-8IMY

Instructions for Form W-8IMY

Department of the Treasury

Internal Revenue Service

(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.

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

IRS.gov/Formw8imy.

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

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.

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

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

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).

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.

Nonqualified intermediary (NQI) that provides an alternative 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.

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

considered to have been made whether it is made directly to

the beneficial owner or to another person, such as an

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.

• 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.

• 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)).

• 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

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).

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

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.

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Instructions for Form W-8IMY (Rev. 10-2021)

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.

• 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 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 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

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.

• 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.

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.

• 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 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 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.

• For withholding under section 1446(f), 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 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 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.

• 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.

• A foreign partnership or foreign grantor trust to establish

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.

• 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

Instructions for Form W-8IMY (Rev. 10-2021)

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.

Do Not Use Form W-8IMY If You Are Described

Below

• You are the beneficial owner (other than a QDD acting in

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.

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• You are a hybrid entity claiming treaty benefits on your

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

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.

• 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

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.

• 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.

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

withholding agent from whom you receive a payment.

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

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.

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.

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/

resource-center/tax-policy/treaties/Pages/FATCAArchive.aspx.

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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

You may provide a single Form W-8IMY if you have

TIP multiple branches receiving payments from the same

withholding agent rather than separate Forms

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.

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).

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Instructions for Form W-8IMY (Rev. 10-2021)

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.

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.

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

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).

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.

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.

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.

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.

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

Instructions for Form W-8IMY (Rev. 10-2021)

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

-5-

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.

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

deemed-compliant FFI (including a reporting Model 1 FFI), or

a QI.

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.

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.

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.

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.

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.

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.

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.

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.

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

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.

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/

resource-center/tax-policy/treaties/Pages/FATCAArchive.aspx.

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Instructions for Form W-8IMY (Rev. 10-2021)

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.

Nonqualified intermediary. Any intermediary that is not

a U.S. person and that is not a qualified intermediary.

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

government is referred to as a reporting Model 1 FFI.

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.

The term reporting IGA FFI refers to both reporting

Model 1 FFIs and reporting Model 2 FFIs.

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).

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:

• 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;

• 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

Instructions for Form W-8IMY (Rev. 10-2021)

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

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.

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any foreign intermediary, foreign partnership, and U.S.

branches of certain foreign banks and insurance companies.

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.

PTP distribution. A PTP distribution is a distribution made

by a PTP.

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).

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.

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

statement for amount realized or PTP distribution in Part IV,

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.

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

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.

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)

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Instructions for Form W-8IMY (Rev. 10-2021)

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.

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

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.

Specific Instructions

Form W-8IMY may be provided to satisfy

TIP documentation requirements for purposes of

Part I — Identification of Entity

withholding on certain partnership allocations to

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,

see QDD withholding statement, later.

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

disregarded entity receiving a payment or maintaining an

account by indicating the name of the disregarded entity on

line 10.

!

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

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

nonparticipating FFI; otherwise, leave line 5 blank. By

checking a box on this line, you are representing that you

qualify for this classification.

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

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

Instructions for Form W-8IMY (Rev. 10-2021)

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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.

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).

For most of the chapter 4 classifications, you are

TIP required to complete additional certifications found in

Parts IX through XXVIII. Complete the appropriate

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.

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

“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.

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

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 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 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 in the process of registering with the IRS as

See www.treasury.gov/resource-center/tax-policy/treaties/

Pages/FATCA-Archive.aspx for a list of jurisdictions treated

as having an IGA in effect.

TIP a participating FFI, registered deemed-compliant FFI

(including a sponsored FFI), reporting Model 1 FFI,

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 7. Enter your mailing address only if it is different from

the address you show on line 6.

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 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

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Instructions for Form W-8IMY (Rev. 10-2021)

Part II — Disregarded Entity or

Branch Receiving Payment

If you are in the process of registering your branch

TIP with the IRS but have not received a GIIN, you may

complete this line by writing “applied for.” However,

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

TIP payment has its own GIIN, Part II should be

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.

Instructions for Form W-8IMY (Rev. 10-2021)

-11-

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.

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.

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.

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

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

TIP accounts, or box 15b or 15c (as applicable) and the

box on line 15f when this form is associated with an

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

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.

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

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):

• 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

!

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

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Instructions for Form W-8IMY (Rev. 10-2021)

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:

• 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;

• 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.

See, For a payment of an amount realized, later, and

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.

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

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

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.

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.

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

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

Instructions for Form W-8IMY (Rev. 10-2021)

-13-

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.

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

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

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;

• $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.

-14-

Instructions for Form W-8IMY (Rev. 10-2021)

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);

• 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.

The QI will complete Form W-8IMY and check the box on

line 14. As QI does not assume primary withholding

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.

See Withholding statement for amount realized or PTP

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

requirements as a participating FFI, QI may report the

amount realized allocable to C and D in a chapter 4

withholding rate pool of U.S. payees.

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.

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:

• Nonparticipating FFI Pool — $20 (which is subject to

chapter 4 withholding);

• Recalcitrant Account Holder Pool — $20 (which is subject

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:

• $20 each on behalf of A and B, two nonresident alien

individuals who are account holders of the QI;

• $10 each on behalf of C and D, two 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;

• $20 on behalf of F, a foreign partnership and account

holder of the QI that has provided the certification and other

Instructions for Form W-8IMY (Rev. 10-2021)

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

-15-

The amount allocable to these two pools under the

alternative procedure excludes amounts allocated to

CAUTION the chapter 4 withholding rate pool of U.S. payees.

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

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

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

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

statement for amount realized or PTP distribution in Part IV,

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:

• 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

• 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.

!

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.

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;

• 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:

• 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);

• 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

for treaty benefits, see Claim of treaty benefits or beneficial

ownership, earlier, for the information required for the claim

(including for a hybrid entity that is a disregarded entity).

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

-16-

Instructions for Form W-8IMY (Rev. 10-2021)

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

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.

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).

If you are required to provide a chapter 4 status on

TIP line 5 and are acting as an intermediary for a

withholdable payment, you must provide your

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.

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

on line 17b applies only to the extent indicated in Withholding

statement for amount realized or PTP distribution, later.

!

A payment that is subject to chapter 3 withholding or

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.

Instructions for Form W-8IMY (Rev. 10-2021)

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.

-17-

• Include the name, address, U.S. TIN (if any), chapter 4

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.

• Allocate each payment by income type to every payee for

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.

• If a payee is identified as a foreign person, specify the rate

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 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:

• 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

payment and the information for the broker to allocate the

amount realized to each transferor; and

• 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

withholding on an amount realized it receives from the

transfer of a PTP interest.

!

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

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.

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

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

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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.

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.

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.

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.

See Withholding statement for amount realized or PTP

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.

Part V — Territory Financial

Institution

Part VI — Certain U.S. Branches

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.

!

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.

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.

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

Instructions for Form W-8IMY (Rev. 10-2021)

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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).

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.

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

realized. See Withholding statement for amount realized or

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

applicable). See Withholding statement, earlier, for the

requirements of a withholding statement provided by an

intermediary for a PTP distribution.

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.

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

trusts providing Form W-8IMY for purposes of section

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).

Part VII — Withholding Foreign

Partnership (WP) or Withholding

Foreign Trust (WT)

Withholding statement of nonwithholding foreign partnership 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

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

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.

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)

If you are providing this Form W-8IMY solely for

requirements outlined for an NQI withholding statement

described earlier.

TIP purposes of section 1446(a) or (f), you are not

required to provide a chapter 4 status because items

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.

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.

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).

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.

See Alternative withholding statement, earlier.

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.

Part IX — Nonparticipating FFI With

Exempt Beneficial Owners

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

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.

You are not required to complete this part unless you

TIP are a nonparticipating FFI providing documentation

on behalf of an exempt beneficial owner.

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).

Instructions for Form W-8IMY (Rev. 10-2021)

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

-21-

Part XV — Certified

Deemed-Compliant Limited Life Debt

Investment Entity

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.

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

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 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.

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)).

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.

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 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

Deemed-Compliant FFI with Only

Low-Value Accounts

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

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.

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).

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.

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Instructions for Form W-8IMY (Rev. 10-2021)

Part XX — Exempt Retirement Plans

status. See Regulations section 1.1472-1(c)(1)(iii) for the

definition of an excepted territory NFFE.

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

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.

!

Part XXVII — Passive NFFE

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

Part XXII — Excepted Nonfinancial

Start-Up Company

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.

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

Instructions for Form W-8IMY (Rev. 10-2021)

-23-

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

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.

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.

Any certifications provided under an applicable IGA

remain subject to the penalties of perjury statement and other

certifications made in Part XXIX.

(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.

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 are not required to provide the information requested

on a form that is subject

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