SECTION 2. DEFINITIONS

Sec. 2.01. Agreement Sec. 2.02. Amounts Subject to NRA Withholding Sec. 2.03. Chapter 3 of the Code Sec. 2.04. Chapter 61 of the Code Sec. 2.05. Distributive Share Sec. 2.06. External Auditor Sec. 2.07. Flow -Through Entity Sec. 2.08. Foreign Person Sec. 2.09. Form W–8

to apply this Section 10.02 to subsequent calendar years. If, however, WP withholds and reports any adjustments required by corrected information in a subsequent calendar year under Section 10.02(4), WP must apply this Section 10.02 to that calendar year in its entirety.

(8) WP and a partnership or trust may not apply this Section 10.02 to any calendar year for which the partnership or trust has failed to make available to WP’s auditor the records described in Section 10.02(1)(c) within 90 days after these records are requested. If, for any calendar year, the partnership or trust has failed to make these records available within the 90-day period, or if WP and the partnership or trust fail to comply with any other requirement of this Section 10.02, WP must apply Treas. Reg. § 1.1441–1 and 1.1441–5 to the partnership or trust, must correct its withholding, and must file corrected Forms 1042 and 1042–S for the calendar year.