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SECTION 14. MISCELLANEOUS PROVISIONS.

Internal Revenue Bulletin 1999-5 · 2026-10-03 edition · updated 2026-10-04 · United States

THIS AGREEMENT is made in duplicate under and in pursuance of section 1441 of the Internal Revenue Code of 1986, as amended, (the “Code”) and Treasury Regulation §1.1441–1(e)(5) by and between [name of QI], any affiliated entities of QI designated in Appendix A of this Agreement that are signatories to this Agreement (collectively referred to as “QI”), and the INTERNAL REVENUE SERVICE (the “IRS”):

WHEREAS, QI has submitted an application in accordance with Revenue Procedure 98–27 to be a qualified intermediary for purposes of Treas. Reg. §1.1441–1(e)(5);

WHEREAS, QI and the IRS desire to enter into an agreement to establish the documentation, withholding, information reporting, tax return filing, deposit obligations, and refund procedures of QI under sections 1441, 1442, 1443, 1461, 3406, 6041, 6042, 6044, 6045, 6049, 6050N, 6302, 6402, 6413, and 6414 of the Code with respect to certain types of payments; NOW, THEREFORE, in consideration of the following terms, representations, and conditions, the parties agree as follows:

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