Code of Federal Regulations Title 26. Internal Revenue § 26.1.565–5 Nonresident aliens and foreign corporations

(a) Withholding. In the event that a corporation makes a consent dividend, as described in § 1.565–1 (a), to a shareholder that is subject to a withholding tax under section 1441 or 1442 on a distribution of cash or other property, the corporation must remit an amount of tax equal to the withholding tax that would be imposed under section 1441 or 1442 if an actual cash distribution equal to the consent dividend had been paid to the shareholder on the last day of the corporation's taxable year. Such payment must be in one of the following forms:

The amount of such payment shall be credited against the tax imposed on the shareholder.