SECTION 11. MISCELLANEOUS

PROVISIONS

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 § 1.1441–5(e)(5)(v) by and between , (referred to as “WT”), and the INTERNAL REVENUE SERVICE (the “IRS”):

WHEREAS, WT has submitted an application in accordance with Revenue Procedure 2003–64 to be a withholding foreign trust for purposes of Treas. Reg. § 1.1441–5(e)(5)(v);

WHEREAS, WT and the IRS desire to enter into an agreement to establish WT's rights and obligations regarding documentation, withholding, information reporting, tax return filing, deposits, and adjustment procedures under sections 1441, 1442, 1443, 1461, 6048, 6302, 6402, 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:

Sec. 2.10. Form W–9 Sec. 2.11. Form 1042 Sec. 2.12. Form 1042–S Sec. 2.13. Form 3520 Sec. 2.14. Form 3520–A Sec. 2.15. Intermediary Sec. 2.16. Nonwithholding Foreign Trust Sec. 2.17. NRA Withholding Sec. 2.18. Overwithholding Sec. 2.19. Payment Sec. 2.20. Pooled Reporting (PR) Election Sec. 2.21. Reduced Rate of Withholding Sec. 2.22. Reportable Amount Sec. 2.23. Reporting Pool Sec. 2.24. TIN Sec. 2.25. Trust and Beneficiary or Owner; Direct, Indirect or Passthrough Beneficiary or Owner Sec. 2.26. Underwithholding Sec. 2.27. U.S. Person Sec. 2.28. Withholding Agent Sec. 2.29. Withholding Foreign Trust (or WT) Sec. 2.30. Withholding Foreign Trust (or WT) EIN Sec. 2.31. Withholding Statement Sec. 2.32. Other Terms