This tax treatment changed rather recently, so you should check this again with more recent information. Fund managers wanted the ability to pass through the dividend/interest tax treatment of U.S. bonds to foreign investors, and Congress honored their request.
I was triggered recently into a googling spree after I read some blog post that highlighted that Stashaway claims that they will claim back some withholding taxes under the "Qualified Interest Income rule":
blog post said:It’s not true that US bonds are subject to 30% with-holding tax. Investor can claim back taxes paid on “Qualified Interest Income” (QII) and government bonds’s interest are usually 100% QII, therefore taxation is 0% after reclaim (and StashAway manages the reclaim).
[...]
Of course, as the StashAway team themselves acknowledged, all this is contingent upon the tax application being successful, as they haven’t had a full tax cycle where they could actually implement this. In tax, nothing is certain until you actually get the tax refund in your hand, so I fully understand their reservations.
This seems to refer to certain tax relief provisions deriving from the American Jobs Creation Act of 2004, as extended, and more recently made permanent in the PATH Act of 2015. These provisions currently exist as Internal Revenue Code section 871(k) "Exemption for certain dividends of regulated investment companies" for non-resident alien individuals, i.e. for "Interest-related dividends" and "Short-term capital gain dividends" (and the corresponding section 881(e) for foreign corporations). I guess this is the recent change mentioned.
An 2015 ICI paper lobbying for this exact change described it as letting foreign investors receive the same tax treatment on interest and short-term capital gains through a U.S. fund, as if they made a direct investment in the underlying securities.
A 2016 Virginia Tax Review article explores the whole U.S. mutual fund tax situation in much more detail, and says that "U.S. source interest and capital gains" are covered but not any "foreign source income".
None of a RIC’s foreign source
income is recharcaterized. In particular, the definition of qualified interest
income is limited to U.S. source interest income — the statute does not
recharacterize foreign source dividends (including similar income such as
Subpart F inclusions and passive foreign investment company inclusions),
interest, swap income, or foreign currency gains.
[...]
Consequently, a distribution of a RIC’s foreign source interest, foreign
source dividends, or swap income is taxed as an ordinary U.S. source
dividend, even though had a foreign shareholder earned the income directly
it would have been exempt from U.S. tax.
I guess the key here is having a broker that will either (i) not withhold entirely, which seems rather unlikely, (ii) withhold and then reclassify next March on Form 1042-S so that you can do tax filing on Form 1040-NR to obtain a refund, or (iii) somehow handle the refund process for you?
Clearstream says that "only the final beneficial owner is allowed to claim such refund directly from the IRS". I can't tell whether this is something only necessary while the tax treatment was non-permanent, or if it's still necessary because it takes time for the funds to report the QII percentages.
Now to see what's the cheapest way to test this out... I'm assuming it would need to be a brokerage located in the U.S. to get a Form 1042-S?
