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Generally, the payee is the person to whom you make the payment, regardless of whether that person is the beneficial owner of the income. However, there are situations in which the payee is a person other than the one to whom you actually make a payment.
U.S. agent of foreign person
If you make a payment to a U.S. person and you have actual knowledge that the U.S. person is receiving the payment as an agent of a foreign person, you must treat the payment as made to the foreign person. However, if the U.S. person is a financial institution, you may treat the institution as the payee provided you have no reason to believe that the institution will not comply with its own obligation to withhold.
If the payment to the U.S. agent of a foreign person is not subject to NRA withholding (e.g., gross proceeds from the sales of securities), you must treat the payment as made to a U.S. person and not as a payment to a foreign person. You may be required to report the payment on Form 1099 and, if applicable, backup withhold.
Disregarded entities
A business entity that is not a corporation and that has a single owner may be disregarded as an entity separate from its owner (a disregarded entity) for federal tax purposes. The payee of a payment made to a disregarded entity is the owner of the entity.
If the owner of the U.S. or foreign disregarded entity is a foreign person, you must apply NRA withholding and reporting but you may be able to treat a foreign owner as a beneficial owner entitled to a reduced rate of withholding.
If the owner of a disregarded entity is documented as a U.S. person, you do not apply NRA withholding. However, you may be required to report the payment on Form 1099 and, if applicable, backup withhold. You must assume that a foreign entity is not a disregarded entity unless you can reliably associate the payment with documentation provided by the owner or you have actual knowledge or reason to know that the foreign entity is a disregarded entity.
Special chapter 4 rules. If you make a withholdable payment to a disregarded entity owned by an FFI, for chapter 4 purposes you must determine whether you must treat the payment as made to a payee that is a nonparticipating FFI (to which chapter 4 withholding applies) or a payee that is an FFI with another chapter 4 status (such as a participating FFI). If you make a withholdable payment to a disregarded entity that is treated as a disregarded entity that is a branch of an FFI that cannot comply with the requirements of an applicable IGA or the regulations under chapter 4, you must treat the payment as made to a nonparticipating FFI and withhold 30% of the payment. See the Instructions for Form W-8BEN-E for more information on payments to disregarded entities.