US Withholding Tax


This course covers all areas of US withholding tax, from the basic terminology and acronyms to processing principles, account structure effects, beneficial owner types and the risks and liability of the models. We also go into detail about the solutions available to financial institutions and current trends and industry initiatives at the time of course delivery.

Who Should Attend?

This course is designed for staff in any financial institution that is impacted by US withholding tax regulations.

This course is particularly useful for those who are part of international tax treaties, or who wish to understand the documentation around US withholding.



What is withholding tax?

  • Terminology and acronyms

Global context and basics

  • Double Tax Treaties
  • Overlap to anti tax avoidance and anti tax evasions regulation

Market Models and Related Issues

  • Relief at Source
  • Quick Refunds
  • Long Form
Processing Principles

Market Model Processes

  • Forms
  • Rules
  • Deadlines
  • Data
  • Dates and submission rules
  • Electronic vs paper processing
  • Statutes of limitation
  • Refund times

Beneficial Owner Types (opaque and transparent)

Account Structure Effects (omnibus, rate pool, segregated)

Special Cases

  • ECJ claims
  • Market claims
  • Manufactured dividends
  • Tax return based claims
  • Depositary claims
  • US, Irish and Japanese QI models
  • FATCA Penalties
  • Section 871(m)
  • Protective claims


  • Measuring process efficiency
  • Mapping service offering to client need
  • Managing statute risk
  • Managing capacity

Risk and Liability

  • Data Protection
  • Liability in the chain of custody

Standards and messaging

  • ISO Messaging
  • Consuming XBRL in Important Notices
  • Proof of withholding
  • Proof of tax residency (certification vs self-certification)
  • Transparent entity claims
  • Tax as a product, not a task
  • Scaling and scoping your business offering
  • Buy, build or outsource
Trends and Industry Initiatives
  • Claims auditing by tax authorities
  • Increasing evidentiary requirements
  • OECD TRACE IP model
  • EU Tax Barriers model
Conclusions and Summary
  • Conclusion
  • Q&A


This course is offered on an in-house basis. Clients will be asked to provide some advance preparatory information which will then be used to customise the course materials so that the material is of more relevance to their situation.

This course can be delivered to a group of between 10 and 40 delegates over a period of either one or two days.

Two day courses cover the same content in more depth, with some additional material, exercises and workshops to help delegates absorb the content more effectively. There is also a greater amount of time allowed for questions, so delegates have the time to structure and ask questions that are relevant to their circumstances.


Please complete our booking form below and we will be in touch to discuss your requirements and to provide a quote.

Contact Us

+44 (0) 1252 413551

Tilsmere House
30 Mill Lane
GU46 7TN