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A party that fails to withhold when required may become liable for the amount of the withholding, as well as penalties and interest under Regs.
Where the service provider demonstrates that the required 15-percent withholding tax will exceed its ultimate Canadian tax liability, CCRA may authorize a reduction in the amount that the Canadian payer is required to withhold. To qualify for reduced withholding, the non-resident must demonstrate that it is entitled to treaty benefits or that its estimated expenses in providing the services in Canada will result in a liability less than the required withholding tax.
Withholding requirements: Generally, a transferee of a USRPI must withhold, report, and pay over to the IRS a tax under Sec.
(16) Under a due process standard, an employer will be required to withhold income tax on wages paid to an employee working in the state to the extent such efforts further the employer's market presence in the state (such as through the in-state solicitation of sales).
The special timing rule and the nonduplication rule apply to deferred compensation only if the employer withholds FICA in the proper amounts at the proper times.