The Chief Counsel of the US Internal Revenue Service (IRS) has issued a memorandum that discusses circumstances under which a withholding agent can rely upon a withholding certificate that is signed with a handwritten signature and electronically submitted to the withholding agent. Under sections 1441 and 1442 of the US Internal Revenue Code (IRC), a withholding agent is generally required to withhold 30% from the gross amount of US source FDAP (fixed or determinable annual or periodical) income paid to a foreign person. The withholding rate can be reduced or eliminated based on an applicable treaty or IRC section if the withholding...