SECTION 5. APPLICATION FOR WP

or WT STATUS

.01 Where to Apply . To apply for WP or WT status, a foreign partnership or trust must submit the information required by this Section 5 to:

Internal Revenue Service LMSB:FS:QI 290 Broadway New York, NY 10007–1867 USA

.02 Contents of the Application . A prospective WP or WT must submit an application to become a WP or WT. An application must include the information specified in this section 5.02, and any additional information and documentation requested by the IRS:

(1) A statement identifying what type of entity the applicant is ( i.e., a foreign partnership or a foreign simple or grantor trust) and that it requests to enter into a WP or WT agreement with the IRS.

(2) The applicant’s name, address, and employer identification number(s) (EIN), if any.

(3) The country in which the applicant was created or organized and a description of the applicant’s business.

(4) A list of the titles of those persons who will be the responsible parties for performance under the Agreement and the names, addresses, and telephone numbers of those persons as of the date the application is submitted.

(5) A list describing, as of the date the application is submitted, the type of partners, beneficiaries or owners ( e.g., U.S., foreign, treaty benefit claimant, or intermediary or flow-through), the number (and percentage interest in partnership capital, partnership profits, and partnership losses (noting any special allocations or similar provisions)) of partners, beneficiaries or owners within each type, and the estimated value of U.S. investments that the WP or WT agreement will cover.

(6) A general description, as of the date the application is submitted, of U.S. assets by type ( e.g., U.S. securities, U.S. real estate), including assets held by U.S. custodians, and their approximate aggregate value by type.

(7) A completed Form SS-4 ( Applica- tion for Employer Identification Number )

June 17, 2002 1156 2002–24 I.R.B.

Avenue, N.W., Washington, D.C. 20224. Mr. Cooper and Ms. Hatten-Boyd may be contacted by telephone at 202–622–3840 (not a toll-free call).

APPENDIX 1

Withholding Foreign Partnership

Agreement