Description
An adviser’s guide to the two withholding regimes that reach a foreign beneficiary of a U.S. estate or trust, backup withholding under section 3406 and chapter 3 withholding, and to the documents that separate them; the presumption rules that decide how an undocumented payee is treated; the cases in which a foreign taxpayer identification number carries a treaty claim and those in which only a U.S. number will do; the treaty map for twelve partner countries; the mechanics of Form W-7 and of the employer identification number for estates and trusts; the TIN matching program and the notice cascade that follows a mismatch; the FIRPTA numbers; the refund path; and the practice points that keep identification ahead of distribution. 24 pages. Updated in September 2026.