Revenue Procedure 2017-21 updates the agreements entered into by withholding foreign partnerships (WPs) and withholding foreign trusts (WTs), as provided in Revenue Procedure 2014-47. These agreements were to expire on December 31, 2016, but were extended in Revenue Procedure 2017-15 in anticipation of the new agreements being issued in January 2017. This revenue procedure will apply to WP and WT agreements effective on or after the date of issuance of this revenue procedure. The WP and WT agreements are updated consistent with recently published guidance, including the qualified intermediary withholding agreement, which was published in Revenue Procedure 2017-15. The revenue procedure also provides information on submitting an application or request for renewal of a WP or WT agreement. This guidance affects WPs and WTs that currently have a WP or WT agreement with the IRS and WPs or WTs that intend to enter into a WP or WT agreement with the IRS in the future.
Revenue Procedure 2017-21 will be in IRB 2017-06, dated February 6, 2017.
Courtesy of IRS
For more information contact Neikirk, Mahoney and Smith at 502-896-2999
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