Where a payer inadvertently fails to withhold
the Regulation 105 tax and no additional payments are owed to a supplier from which under-withheld tax can be recouped, the Canadian payer will bear the burden of the tax.
If the IRS issues the requested certificate, it entitles the transferee to withhold
a lesser amount, or exempts the sale from withholding altogether, depending on the specific circumstances of the foreclosure sale.
* Provided employers with consistent guidelines on how to withhold
income tax from employee wages;
The regulations also allow the employer to withhold
on any date that is no more than three months after the date the amount is required to be taken into account.
The payor or broker does not require certification on the recipient's exempt status, but withholds