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United States: Withholding foreign partnership, withholding foreign trust agreements

United States: WP and WT agreements

The IRS on 19 January 2017 released an advance version of Rev. Proc. 2017-21 that contains the final withholding foreign partnership agreement (WP agreement) and withholding foreign trust agreement (WT agreement).


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Rev. Proc. 2017-21 explains that the WP and WT agreements generally allow a foreign partnership or foreign trust to assume the withholding and reporting obligations under Code chapters 3 and 4 for certain payments of U.S. source income (such as interest, dividends, and royalties) made to its direct partners, beneficiaries, or owners, and in some cases, persons holding interests in the partnership or trust through one or more foreign intermediaries or flow-through entities (indirect partners). 

Rev. Proc. 2017-21 also provides guidance to foreign partnerships and foreign trusts for how to apply to enter into, or renew, the WP or WT agreement.


Read a January 2017 report [PDF 70 KB] prepared by the KPMG member firm in the United States

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