DCarsonCPA The Reading Rooms

DCarsonCPA The Reading Rooms - a sketch draft in review

A knowledge driven business thrives on continual learning, development and growth. As we move forward we find significant important lines that can contribute to the complex needs on consulting and the very simple lines of it all reverts back to the needs for strong and compliant financials, insight for management consulting / advisory,  and the key point that learning in a vacuum is unsustainable.  A pipeline of new ideas and continual learning in support of the strategic and operational overlays to the base line of financials for decision makers.

The Financials and Compliance are the foundation - if handled correctly they produce a strong foundation
 for analysis to look at the business or entity financials and then map them out to the broader economy to use technology and help support the lines for  economic growth and  opportunity lines. Opportunity seeking in the Economy and competing for the lines of supply and demand are par for the course in business and we reconnect accounting to it's economic perspective on strategy.

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Just a few of the many points on knowledge plus services from www.dcarsoncpa.com

DCarsonCPA on Insurance

DCarsonCPA sketch draft on Insurance. Will return soon to expand.

Mapping in the Resources

Current Awareness

Insurance / Risk Management http://paper.li/DCarsonCPA_CT/1379507434

Pensions http://paper.li/DCarsonCPA_CT/1380935872

Investment Management http://paper.li/DCarsonCPA_CT/1380083052

Support Services

Insurance http://dcarsoncpa.com/strategic/insurance

Pensions and Employee Benefits.http://dcarsoncpa.com/addtl_sources/labor_and_pensions

Investment Management http://dcarsoncpa.com/strategic/investment_management

Outlining the Needs on Deductions and Witholdings of Tax on Payments for Foreign Persons § 1.1441-1 (It's complicated)

Outlining the Needs on Deductions and Witholdings of Tax on Payments for Foreign Persons § 1.1441-1   .... ( In a word... It's complicated).


This is an outline of the structure for the Rules to fill into and we can help on your needs if you are a "Foreign" or Non-US Resident with US Tax Requirements. You can learn more of us at DCarsonCPA - we are a practice that works with knowledge, experience, teamwork, domestic and global research for the Client needs on Accounting, Taxes, Financials, Compliance and more. We work with Technology that can help on Financial Decision Making.

For your reading on Taxes below:

§ 1.1441-0   Outline of regulation provisions for section 1441.

This section lists captions contained in §§ 1.1441-1 through 1.1441-9.

§ 1.1441-1   Requirement for the deduction and withholding of tax on payments to foreign persons.

(a) Purpose and scope.
(b) General rules of withholding.
(1) Requirement to withhold on payments to foreign persons.
(2) Determination of payee and payee's status.
(i) In general.
(ii) Payments to a U.S. agent of a foreign person.
(iii) Payments to wholly-owned entities.
(A) Foreign-owned domestic entity.
(B) Foreign entity.
(iv) Payments to a U.S. branch of certain foreign banks or foreign insurance companies.
(A) U.S. branch treated as a U.S. person in certain cases.
(B) Consequences to the withholding agent.
(C) Consequences to the U.S. branch.
(D) Definition of payment to a U.S. branch.
(E) Payments to other U.S. branches.
(v) Payments to a foreign intermediary.
(A) Payments treated as made to persons for whom the intermediary collects the payment.
(B) Payments treated as made to foreign intermediary.
(vi) Other payees.
(vii) Rules for reliably associating a payment with a withholding certificate or other appropriate documentation.
(A) Generally.
(B) Special rules applicable to a withholding certificate from a nonqualified intermediary or flow-through entity.
(C) Special rules applicable to a withholding certificate provided by a qualified intermediary that does not assume primary withholding responsibility.
(D) Special rules applicable to a withholding certificate provided by a qualified intermediary that assumes primary withholding responsibility under chapter 3 of the Internal Revenue Code.
(E) Special rules applicable to a withholding certificate provided by a qualified intermediary that assumes primary Form 1099 reporting and backup withholding responsibility but not primary withholding under chapter 3.
(F) Special rules applicable to a withholding certificate provided by a qualified intermediary that assumes primary withholding responsibility under chapter 3 and primary Form 1099 reporting and backup withholding responsibility and a withholding certificate provided by a withholding foreign partnership.
(3) Presumptions regarding payee's status in the absence of documentation.
(i) General rules.
(ii) Presumptions of classification as individual, corporation, partnership, etc.
(A) In general.
(B) No documentation provided.
(C) Documentary evidence furnished for offshore account.
(iii) Presumption of U.S. or foreign status.
(A) Payments to exempt recipients.
(B) Scholarships and grants.
(C) Pensions, annuities, etc.
(D) Certain payments to offshore accounts.
(iv) Grace period.
(v) Special rules applicable to payments to foreign intermediaries.
(A) Reliance on claim of status as foreign intermediary.
(B) Beneficial owner documentation or allocation information is lacking or unreliable.
(C) Information regarding allocation of payment is lacking or unreliable.
(D) Certification that the foreign intermediary has furnished documentation for all of the persons to whom the intermediary certificate relates is lacking or unreliable.
(vi) U.S. branches.
(vii) Joint payees.
(A) In general.
(B) Special rule for offshore accounts.
(viii) Rebuttal of presumptions.
(ix) Effect of reliance on presumptions and of actual knowledge or reason to know otherwise.
(A) General rule.
(B) Actual knowledge or reason to know that amount of withholding is greater than is required under the presumptions or that reporting of the payment is required.
(x) Examples.
(4) List of exemptions from, or reduced rates of, withholding under chapter 3 of the Code.
(5) Establishing foreign status under applicable provisions of chapter 61 of the Code.
(6) Rules of withholding for payments by a foreign intermediary or certain U.S. branches.
(i) In general.
(ii) Example.
(7) Liability for failure to obtain documentation timely or to act in accordance with applicable presumptions.
(i) General rule.
(ii) Proof that tax liability has been satisfied.
(iii) Liability for interest and penalties.
(iv) Special effective date.
(v) Examples.
(8) Adjustments, refunds, or credits of overwithheld amounts.
(9) Payments to joint owners.
(c) Definitions.
(1) Withholding.
(2) Foreign and U.S. person.
(3) Individual.
(i) Alien individual.
(ii) Nonresident alien individual.
(4) Certain foreign corporations.
(5) Financial institution and foreign financial institution.
(6) Beneficial owner.
(i) General rule.
(ii) Special rules.
(A) General rule.
(B) Foreign partnerships.
(C) Foreign simple trusts and foreign grantor trusts.
(D) Other foreign trusts and foreign estates.
(7) Withholding agent.
(8) Person.
(9) Source of income.
(10) Chapter 3 of the Code.
(11) Reduced rate.
(12) Payee.
(13) Intermediary.
(14) Nonqualified intermediary.
(15) Qualified intermediary.
(16) Withholding certificate.
(17) Documentary evidence; other appropriate documentation.
(18) Documentation.
(19) Payor.
(20) Exempt recipient.
(21) Non-exempt recipient.
(22) Reportable amounts.
(23) Flow-through entity.
(24) Foreign simple trust.
(25) Foreign complex trust.
(26) Foreign grantor trust.
(27) Partnership.
(28) Nonwithholding foreign partnership.
(29) Withholding foreign partnership.
(d) Beneficial owner's or payee's claim of U.S. status.
(1) In general.
(2) Payments for which a Form W-9 is otherwise required.
(3) Payments for which a Form W-9 is not otherwise required.
(4) When a payment to an intermediary or flow-through entity may be treated as made to a U.S. payee.
(e) Beneficial owner's claim of foreign status.
(1) Withholding agent's reliance.
(i) In general.
(ii) Payments that a withholding agent may treat as made to a foreign person that is a beneficial owner.
(A) General rule.
(B) Additional requirements.
(2) Beneficial owner withholding certificate.
(i) In general.
(ii) Requirements for validity of certificate.
(3) Intermediary, flow-through, or U.S. branch withholding certificate.
(i) In general.
(ii) Intermediary withholding certificate from a qualified intermediary.
(iii) Intermediary withholding certificate from a nonqualified intermediary.
(iv) Withholding statement provided by nonqualified Intermediary.
(A) In general.
(B) General requirements.
(C) Content of withholding statement.
(D) Alternative procedures.
(E) Notice procedures.
(v) Withholding certificate from certain U.S. branches.
(vi) Reportable amounts.
(4) Applicable rules.
(i) Who may sign the certificate.
(ii) Period of validity.
(A) Three-year period.
(B) Indefinite validity period.
(C) Withholding certificate for effectively connected income.
(D) Change in circumstances.
(iii) Retention of withholding certificate.
(iv) Electronic transmission of information.
(A) In general.
(B) Requirements.
(C) Special requirements for transmission of Forms W-8 by an intermediary. [Reserved]
(v) Electronic confirmation of taxpayer identifying number on withholding certificate.
(vi) Acceptable substitute form.
(vii) Requirement of taxpayer identifying number.
(viii) Reliance rules.
(A) Classification.
(B) Status of payee as an intermediary or as a person acting for its own account.
(ix) Certificates to be furnished for each account unless exception applies.
(A) Coordinated account information system in effect.
(B) Family of mutual funds.
(C) Special rule for brokers.
(5) Qualified intermediaries.
(i) General rule.
(ii) Definition of qualified intermediary.
(iii) Withholding agreement.
(A) In general.
(B) Terms of the withholding agreement.
(iv) Assignment of primary withholding responsibility.
(v) Withholding statement.
(A) General rule.
(B) Content of withholding statement.
(C) Withholding rate pools.
(f) Effective date.
(1) In general.
(2) Transition rules.
(i) Special rules for existing documentation.
(ii) Lack of documentation for past years.



DCarsonCPA is your webline to the practice of Dean T. Carson II, CPA where the solution set works with Knowledge, Experience, Teamwork and Research to meet the needs of Financial Decision Makers in Entity, Non Profits, Governance and Individual / Family roles on Financials. Please learn more at www.dcarsoncpa.com 

SEC Definition of Investment Performance of an Investment Company

SEC Definition of Investment Performance of an Investment Company:

§ 275.205-1 Definition of “investment performance” of an investment company and “investment record” of an appropriate index of securities prices.

The above citation has been provided as an illustration of a connecting point between Governance, Accounting, Financials, Economics, Statistics and the Investment Management Industry. Please note the following disclaimer:

Note: Citation As of Read Date 1/3/2013, ALL SEC Rules are subject to change and update and you must Independently confirm as filing or relying. The citation is provided here as an illustration of converging points of Financials, Finance, Governance and Quantitative measures (of Economics and Statistics) as relevant to the Investment Management Industry. The Citation is NOT for Reliance and NOT for Advice. 

We support Client needs on Financials and Compliance on Services and welcome your inquiries on where we may meet on services. For Any Legal needs it is recommended that you connect with an Attorney through your local State Bar Chapter. 

DCarsonCPA is your weblink to Our Practice where knowledge, experience, teamwork and research connect for Client support services on Accounting, Financials, Taxes, Advisory, Project and Legal Support Services (for Attorney's) we are interested to hear of your needs on projects and work with signifcant streams of research to support Financial Decision Makers with complex needs in the Economy. Please learn more at www.dcarsoncpa.com or e-mail info@dcarsoncpa.com