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Dec 16, 2014 13:08
10 yrs ago
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English term
"disregarded entity" vs "fiscally transparent entity"
English to Russian
Bus/Financial
Law: Taxation & Customs
FATCA
Подскажите, пожалуйста, как корректно перевести термин "disregarded entity" в контексте FATCA:
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 this Form W-8BEN-E 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). See Regulations section 1.1446-1 and section 1.1471-3(a)(3)(v), respectively. However, if a disregarded entity receiving a withholdable payment is an FFI outside the single owner’s country of organization, the owner will be required to complete Part II of Form W-8BEN-E to document the chapter 4 status of the disregarded entity receiving the payment.
В том же документе встречается термин "Fiscally transparent entity", как правильно разграничить эти термины? Заранее спасибо.
Fiscally transparent entity. An entity is treated as fiscally transparent with respect to an item of income for which treaty benefits are claimed 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.
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 this Form W-8BEN-E 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). See Regulations section 1.1446-1 and section 1.1471-3(a)(3)(v), respectively. However, if a disregarded entity receiving a withholdable payment is an FFI outside the single owner’s country of organization, the owner will be required to complete Part II of Form W-8BEN-E to document the chapter 4 status of the disregarded entity receiving the payment.
В том же документе встречается термин "Fiscally transparent entity", как правильно разграничить эти термины? Заранее спасибо.
Fiscally transparent entity. An entity is treated as fiscally transparent with respect to an item of income for which treaty benefits are claimed 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.
Proposed translations
(Russian)
5 | не принимаемое во внимание лицо и фискально-прозрачное лицо | Igor Kondrashkin |
Proposed translations
2 hrs
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